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NATIONAL RENEWABLE ENERGY LABORATORY 

ENVIRONMENTAL REPORT 

FOR 

2001

Prepared by: 

Environment, Safety & Health Office 

National Renewable Energy Laboratory 

NREL is a national laboratory of the 

U.S. Department of Energy and is 

operated by Midwest Research Institute, Battelle, 

and Bechtel 

September 2002 
NREL Environmental Report – 2001 Page 2 

TABLE OF CONTENTS 

1. INTRODUCTION ................................................................................................................................ 4

1.1. PURPOSE .......................................................................................................................................... 4

1.2. BACKGROUND ................................................................................................................................. 4

1.3. SITE AND FACILITY DESCRIPTION ................................................................................................... 5

2. SITE ENVIRONMENTAL CONDITIONS/FEATURES ............................................................... 10

2.1. SOUTH TABLE MOUNTAIN SITE ..................................................................................................... 10

2.2. NATIONAL WIND TECHNOLOGY CENTER ...................................................................................... 12

2.3. DENVER WEST OFFICE PARK ........................................................................................................ 13

2.4. JOYCE STREET FACILITY ............................................................................................................... 13

2.5. METEOROLOGY ............................................................................................................................. 13

3. ENVIRONMENTAL PROGRAMS .................................................................................................. 18

3.1. AIR QUALITY PROTECTION ........................................................................................................... 18

3.1.1. Program Management .......................................................................................................... 18

3.1.2. Permitting ............................................................................................................................. 19

3.1.3. 2001 Activities ...................................................................................................................... 20

3.2. DRINKING WATER ......................................................................................................................... 20

3.2.1. Program Management .......................................................................................................... 20

3.2.2. Permitting ............................................................................................................................. 21

3.2.3. 2001 Activities ...................................................................................................................... 22

3.3. GROUND WATER PROTECTION ...................................................................................................... 22

3.3.1. Program Management .......................................................................................................... 22

3.3.2. Permitting ............................................................................................................................. 24

3.3.3. 2001 Activities ...................................................................................................................... 24

3.4. WASTEWATER DISCHARGE ........................................................................................................... 24

3.4.1. Program Management .......................................................................................................... 24

3.4.2. Permitting ............................................................................................................................. 25

3.4.3. 2001 Activities ...................................................................................................................... 25

3.5. SURFACE WATER PROTECTION (STORM WATER) .......................................................................... 25

3.5.1. Program Management .......................................................................................................... 25

3.5.2. Permitting ............................................................................................................................. 26

3.5.3. 2001 Activities ...................................................................................................................... 26

3.6. WASTE MANAGEMENT .................................................................................................................. 27

3.6.1. Program Management .......................................................................................................... 27

3.6.2. Permitting ............................................................................................................................. 29

3.6.3. 2001 Activities ...................................................................................................................... 29

3.7. STORAGE TANKS (UNDERGROUND AND ABOVE GROUND) ............................................................ 29

3.7.1. Program Management .......................................................................................................... 29

3.7.2. Permitting ............................................................................................................................. 30

3.7.3. 2001 Activities ...................................................................................................................... 30

3.8. HAZARDOUS MATERIALS MANAGEMENT ...................................................................................... 31

3.8.1. Program Management .......................................................................................................... 31

3.8.2. Permitting ............................................................................................................................. 33

3.8.3 2001 Activities ...................................................................................................................... 33

3.9. VEGETATION MANAGEMENT ........................................................................................................ 33

3.9.1 Program Management .......................................................................................................... 33

3.9.2 Permitting ............................................................................................................................. 35

3.9.3 2001 Activities ...................................................................................................................... 35

3.10. ENDANGERED SPECIES/SPECIES OF CONCERN ........................................................................... 36

3.10.1. Program Management .......................................................................................................... 36

3.10.2 Permitting ............................................................................................................................. 37

3.10.3 2001 Activities ...................................................................................................................... 37

3.11. WETLANDS/FLOODPLAINS......................................................................................................... 38

3.12. CULTURAL RESOURCES ............................................................................................................. 38
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3.13. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) .................................................................. 39

3.13.1. Program Management .......................................................................................................... 39

3.13.2. Permitting ............................................................................................................................. 39

3.13.3. 2001 Activities ...................................................................................................................... 39

3.14. RADIOLOGICAL PROGRAM......................................................................................................... 40

3.14.1 Program Management .......................................................................................................... 40

3.14.2 Permitting ............................................................................................................................. 42

3.14.3 2001 Activities ...................................................................................................................... 43

4. GREENING OF THE GOVERNMENT THROUGH LEADERSHIP IN ENVIRONMENTAL 

MANAGEMENT ........................................................................................................................................ 43

5. CONSERVATION EASEMENT LANDS ........................................................................................ 46

6. NON-ROUTINE ACTIVITIES/SPECIAL PROJECTS ................................................................. 47

7. ENVIRONMENTAL OCCURRENCES .......................................................................................... 47

8. SUMMARY OF ONGOING ENVIRONMENTAL ACTIVITIES ................................................ 47

9. REFERENCES ................................................................................................................................... 48

10. APPENDICES ................................................................................................................................. 49

LIST OF FIGURES 

Figure 1.1 – Regional Map ..................................................................................................7 

Figure 1.2 – STM Site Detail ...............................................................................................8 

Figure 1.3 – NWTC Site Detail ...........................................................................................9 

Figure 2.1 - South Table Mountain Site – N View ............................................................15 

Figure 2.2 - South Table Mountain Site – NW View ........................................................15 

Figure 2.3 - South Table Mountain Site – E View ............................................................16 

Figure 2.4 – South Table Mountain Site – SE View ..........................................................16 

Figure 2.5 – NWTC Site – NW View ...............................................................................17 

Figure 2.6 – NWTC Site – NW View with Turbine ..........................................................17 
NREL Environmental Report – 2001 Page 4 

1. INTRODUCTION 

The National Renewable Energy Laboratory (NREL) is a U.S. Department of Energy 

(DOE) national laboratory, and conducts research primarily for DOE’s Office of Energy 

Efficiency and Renewable Energy (EERE). NREL is operated by the Midwest Research 

Institute, Battelle, and Bechtel under the oversight of the DOE Golden Field Office (GO). 

NREL is the nation's lead laboratory for developing and advancing renewable energy 

technologies and a primary laboratory for energy efficiency technologies. 

1.1. Purpose 

This report presents a summary of NREL’s environmental protection programs 

and activities for 2001. It is organized according to the different environmental 

media (e.g. air, waste, ground water, etc.), and includes a brief summary of how 

the program is managed in that area, any permitting or notification efforts that 

have been completed during the reporting period or are ongoing, and activities 

that have occurred during the reporting period in that environmental area. A 

description of the environmental condition and features of NREL’s sites is also 

included to provide a basis for the program overview. 

1.2. Background 

NREL’s mission: NREL develops renewable energy and energy efficiency 

technologies and practices, advances related science and engineering, and 

transfers knowledge and innovations to address the nation’s energy and 

environmental goals. 

NREL fulfills its mission through technology portfolios; a brief description of 

each major technology area follows. 

Photovoltaics: Photovoltaics is the direct conversion of sunlight to electricity 

using solid-state materials. The National Center for Photovoltaics develops and 

deploys photovoltaic (PV) technology for the generation of electric power. 

Wind Energy: Through the National Wind Technology Center, NREL develops, 

improves, and demonstrates the viability of wind technology for electricity 

generation and facilitates its deployment throughout the world 

Bioenergy: NREL currently has major programs in both biomass-derived fuels 

(biofuels) and biomass-derived electricity (biopower), and projects in biomassderived chemicals and materials. 

Renewable Thermal Technologies: These technologies generate power from heat 

or utilize heat from renewable resources. They include concentrating solar 

power, solar water heating, and geothermal heat and power. 

Distributed Power: Distributed power is modular electric generation or storage 

located near the point of use. NREL participates in the development of 
NREL Environmental Report – 2001 Page 5 

technologies, market structures, and policies that affect the incorporation of 

renewables and energy efficiency technologies in distributed power systems, 

maximizing the deployment of renewable energy and energy efficiency products. 

As a part of this initiative, NREL is involved in the development, design, and 

deployment facilitation of renewable and renewable/fossil hybrid distributed 

power systems in grid-connected applications. 

Building Energy: NREL increases the use of energy efficiency technologies and 

expands the use of renewable energy technologies in the building sector by 

working to develop new, cost-effective, and environmentally acceptable building 

equipment and envelope systems. 

Hydrogen: NREL serves as a leader in renewable hydrogen production 

technologies as well as in advanced storage and sensor development. Basic and 

applied research and material development using biology, physics, and chemistry 

enable and support the development of hydrogen production, storage, and enduse systems. 

Advanced Vehicles: NREL works with industry to develop advanced vehicles 

and systems for transportation, and to develop viable vehicle systems that are 

integral to DOE transportation initiatives. 

Advanced Fuels: NREL works with energy companies and manufacturers of 

vehicles and engines to develop advanced motor vehicle fuels for improved 

energy and environmental performance. A systems approach is used to develop 

optimized engine management, fuel, and emission control technologies. 

Basic Science: The basic science that underlies NREL’s technologies is 

currently focused on materials growth and analysis for photovoltaics and related 

technologies; solid-state theory and characterization; superconductivity; 

advanced materials and concepts such as semiconductors and metals; 

photoconversion, which is using innovative approaches to converting solar 

photons to fuels, chemicals, and electricity; electrochemistry as applied to fuel 

cells, solar hydrogen production, advanced batteries, and electrochromic devices; 

catalyst design that includes converting carbon dioxide to fuels and products; and 

microbiology and biochemistry applied to converting biomass into energy and 

products. 

1.3. Site and Facility Description 

NREL facilities occupy four separate locations in Jefferson County, Colorado, 

near the city of Denver. The four facilities are the Denver West Office Park 

(DWOP), the South Table Mountain site (STM), the Joyce Street Facility (JSF), 

and the National Wind Technology Center (NWTC). The DWOP and STM sites 

are approximately 2 miles (3.2 km) east of Golden and 12 miles (19.3 km) west 

of central Denver. The NWTC is located near the intersection of Highways 93 

and 128, between Boulder and Golden, and is approximately 15 miles (24.2 km) 

north of the STM site. It is adjacent to the DOE Rocky Flats Environmental 
NREL Environmental Report – 2001 Page 6 

Technology Site. The JSF is located at 6800 Joyce Street, approximately 5.5 

miles (8.9 km) north of the DWOP and STM sites. Figure 1.1 illustrates the 

locations of all of the sites, except the JSF site on a regional map. Figure 1.2 

provides a more detailed map of the STM site, and Figure 1.3 gives a more 

detailed map of the NWTC site. 

The STM and NWTC sites are the two main sites where research operations are 

conducted. These two sites will be addressed separately in the discussion of 

environmental features. The DWOP is leased space used primarily for 

administrative functions and limited research activities. The JSF is also a leased 

space that is used for storage. 
NREL Environmental Report – 2001 Page 7 

Figure 1.1 – Regional Map 
NREL Environmental Report – 2001 Page 8 

INSERT 

Figure 1.2 – STM Site Detail 

HERE 
NREL Environmental Report – 2001 Page 9 

INSERT 

Figure 1.3 – NWTC Site Detail 

HERE 
NREL Environmental Report – 2001 Page 10 

2. SITE ENVIRONMENTAL CONDITIONS/FEATURES 

Photos for each site documenting the site features and development, as they existed 

during 2000 and 2001, are included at the end of this section. Figures 2.1, 2.2, 2.3 and 

2.4 illustrate the South Table Mountain site, and Figures 2.5 and 2.6 illustrate the 

National Wind Technology Center site. The views on the STM site also illustrate the 

Conservation Easement property and the Camp George West property acquired in 1999. 

2.1. South Table Mountain Site 

Geology, Soils, and Hydrogeology 

The STM site is a roughly triangular parcel of land occupying portions of the 

top, sides, and lower south-facing slopes of South Table Mountain. South Table 

Mountain is composed of sedimentary rocks below a basalt lava cap, which is 

quite resistant to erosion. The South Table Mountain feature is a mesa that 

stands about 150 meters above the adjacent lowlands. It was formed by the 

erosion of weak sedimentary rocks surrounding the mesa's erosion resistant lava 

cap. Below the lava caprock, the sedimentary rocks are part of the Denver 

Formation that consists of layers and lenses of claystone, sandstone, and 

conglomerate. Sedimentary rocks of the Arapahoe Formation underlie the 

Denver Formation. 

Both the Arapahoe and Denver Formations are considered to be aquifers in 

portions of the Denver Basin. The Denver Formation underlies the areas on 

which most NREL construction has taken place. Groundwater on the STM site 

occurs primarily in the weathered and fractured silts and sands of the Denver 

Formation. There may also be some groundwater in the form of perched aquifers 

below the basaltic lava cap on the South Table Mountain and within the 

materials above the Denver Formation, which are largely the result of stream 

deposits. Groundwater flow on the site is in a southeasterly direction. 

The soil covering the top of South Table Mountain is Lavina Loam. A loam is 

composed of a mixture of clay, sand, silt, and organic matter. The loam on the 

mesa top is a shallow, well-drained clayey soil. Soil on the upper side slopes of 

South Table Mountain is also a loam consisting of extremely stony soils with 

significant amounts of clay. Much of the remainder of the site, including the 

area designated for major development, has a deep, well-drained soil referred to 

as Denver clay loam. It consists of clayey material containing some calcium 

carbonate. There are also two smaller soil areas on the southwestern portion of 

the site, both of similar character to other site soils: cobbly clay loam and very 

stony clay loam. 

Surface Water 

About 90% of the surface drainage off the site, both the mesa top and across the 

lower portions of the site, is in the southerly direction toward Lena Gulch (a 

tributary of Clear Creek). Two drainageways on the easternmost portion of the 

site are intercepted by Welch Ditch, which ultimately flows into Lena Gulch. 
NREL Environmental Report – 2001 Page 11 

There is no permanent stream flow on the STM site. Only occasional flow 

derived from extended periods of precipitation, usually during the late winter and 

early spring, is found in the drainage channels with seasonal springs evident 

along some of the mesa slopes. There is one seep on the mesa top that is active 

throughout most of the year, but the water infiltrates and evaporates quickly 

during dry times of the year. 

Vegetation 

Two primary vegetation types are present on the STM site: grasslands and 

shrublands. The most common plant communities on the STM site are mixed 

grasslands, comprising over 80% of the vegetation on the site. These 

communities are generally dominated by short- and mid-grass species. Two 

primary upland shrub communities occur on the STM site: mountain mahogany 

shrublands, found on the shallow soils of the mesa, and upland shrublands, 

occurring in drainages lacking active channels as well as drainages with 

associated wetlands. Recent field surveys have identified limited 

wetland/riparian areas along drainages. The wetland communities identified on 

the STM site are a very minor component of the total vegetation cover, 

accounting for less than 1% of the vegetation over an area of less than 0.3 ha 

(0.75 ac). Riparian shrub communities also occur adjacent to the emergent 

wetlands. 

Wildlife 

A wildlife survey was conducted on the site during 1986 and 1987, and 

additional surveys were done in 1999 over the Conservation easement property. 

Mammals seen using the site during the survey were the mule deer, coyote, grey 

fox, red fox, raccoon, longtailed weasel, striped skunk, spotted skunk, badger, 

bobcat, mountain lion, rabbits, and yellow-bellied marmots. Seventeen species 

of birds were observed on the STM site, along with two species of raptors: 

kestrels and two nesting pairs of red-tailed hawks. NREL personnel have 

reported numerous sightings of snakes as well as a golden eagle. A variety of 

amphibian species are expected to inhabit the area. 

Land Use 

The STM site is a 325-acre area predominantly bordered by open grassland 

zoned for recreation and light-commercial activity. Portions of the community 

of Pleasant View are located immediately to the south and west of the western 

portions of the STM site. Pleasant View is currently planning a recreational park 

immediately south of the STM site. Offices, shops, and a tree nursery owned by 

the Colorado State Forest Service are located at the far western edge. 

Undeveloped state land and a Colorado State Highway Patrol pursuit driver 

training track are located along the northwestern boundary of the STM site. 

Jefferson County open space wraps around the northern and the eastern edge of 

the site. Portions of the DWOP and apartment homes lie to the east. 

More than half of the STM site (177 acres) has been set aside in a Conservation 

Easement. No development is allowed on that land, with the exception of some 
NREL Environmental Report – 2001 Page 12 

existing utility easements and recreational trails to be established by Jefferson 

County Open Space. 

2.2. National Wind Technology Center 

Geology, Soils, and Hydrogeology 

The NWTC site is located on a plain formed by stream deposits. The uppermost 

geological layer beneath the site is known as the Rocky Flats Alluvium (RFA). 

It is composed of cobbles, coarse gravel, sand, and gravelly clay. Below the 

RFA are the Laramie Formation, Fox Hills Sandstone, and Pierre Shale. These 

rock formations consist primarily of claystones with some siltstones. 

Unconfined groundwater flow occurs in the RFA toward the east/southeast, and 

small perched zones are common. Groundwater occurs as confined aquifers in 

the deeper bedrock formations (EG&G Rocky Flats, Inc., 1992). 

The NWTC has a strongly developed soil defined as a very cobbly, sandy loam. 

The soil is characterized by a large amount of cobble and gravel in the soil 

volume, and a subsoil dominated by clay (USDA, 1995). 

Surface Water 

The area surrounding the NWTC site is drained by five streams: Rock Creek, 

North Walnut Creek, South Walnut Creek, Woman Creek, and Coal Creek. 

Rock Creek flows eastward and is located southeast of the NWTC. North 

Walnut Creek and South Walnut Creek flow eastward into the Great Western 

Reservoir. Woman Creek drains eastward into Standley Lake. Coal Creek flows 

in a northeasterly direction across the City of Boulder open space north of the 

NWTC. 

The majority of the NWTC drains into a tributary to Rock Creek. Some of the 

northern portions of the site drain into Coal Creek or its tributaries. 

Vegetation 

The NWTC is located in the transition area between the Great Plains and the 

Rocky Mountains (Plantae Consulting Services, 2000). This location results in a 

flora that contains elements from both mountain and prairie ecosystems and 

associations that represent residual tall grass prairie, short-grass plains, 

ponderosa pine woodland, and foothill ravine flora (Plantae Consulting Service, 

2000). 

A vegetation study conducted between August 1999 and August 2000 identified 

271 vascular plant species and defined five major habitat types on the NWTC 

site including the following: Seasonal wetlands/or ephemeral hydric soils, 

woodlands, shrublands, mixed grasslands, and disturbed areas. 

Along the Northwestern ridge is a Ponderosa pine woodland area. Vegetation 

found in this area includes woody species with an understory of grasses, forbs, 

and shrubs. 
NREL Environmental Report – 2001 Page 13 

Wildlife 

Prior to 1975, the NWTC site was heavily grazed by livestock, damaging a 

majority of the native vegetation. A wildlife survey was conducted in 1992 for 

the entire Rocky Flats Plant and buffer zone area, including the NWTC site. 

Signs or tracks of bears and mountain lions were identified. Other mammals 

known to feed at the site are mule deer, coyotes, desert cottontail rabbits, whitetailed jackrabbits, black-tailed jackrabbits, deer mice, prairie voles, and thirteenlined ground squirrels. Approximately 20 different species of birds were sighted 

at or near the site. Raptor (birds of prey) surveys were conducted at the NWTC 

in 1994 and 1995, and identified seven raptor species on or in the vicinity of the 

site. 

Land Use 

The NWTC facility occupies a 305-acre area surrounded by open grazing land, 

with the exception of operations at the Rocky Flats Environmental Technology 

Site, which borders the NWTC to the southeast, and a sand and gravel mining 

operation along the southern and western boundaries of the site. A blasting 

company also has a small installation along the western site boundary. 

A piece of land of about 25 acres, located at the southeast corner of the NWTC, 

was recently designated for inclusion within the NWTC by the National Defense 

Authorization Act (see Figure 1.3). Two test sites and unimproved roads are 

located on this land. The transfer of this land parcel from DOE Rocky Flats 

should be completed later in 2002.

2.3. Denver West Office Park 

The DWOP is a relatively flat, landscaped office complex occupied by a number 

of four-story buildings, parking lots, and common areas. NREL-leased facilities 

at DWOP are located approximately in the geographic center of the 

development. The DWOP is bordered on the south by commercial areas (West 

Colfax strip); on the west by the Pleasant View residential area, Camp George 

West facility, and the STM site. DWOP is within the City of Lakewood. 

2.4. Joyce Street Facility 

The JSF is located in a commercial area surrounded by agricultural land, 

residential neighborhoods, and small businesses. It is currently used by NREL as 

warehouse space only. No research or support activities are conducted at the 

facility, and there are no staff offices at JSF. 

2.5. Meteorology 

The climate for the geographic region of NREL operations is classified as semiarid, typified by sparse precipitation, low relative humidity, abundant sunshine, 

and large daily and seasonal temperature variations. 
NREL Environmental Report – 2001 Page 14 

The area experiences moderate precipitation, with average annual rainfall less 

than 50 cm (20 in). Almost half of the annual precipitation occurs from March to 

June. Summer showers contribute 33% of the annual precipitation total. 

Precipitation begins to decrease significantly in the fall, and reaches the 

minimum during winter. Winter is the driest season, contributing less than 10% 

of the annual precipitation, primarily in the form of snowfall. 

Spring is a season of unstable air masses with strong winds along the foothills 

and the Front Range. The highest average snowfall occurs in March, and the 

STM site can generally expect to experience at least one heavy snowstorm with 

totals exceeding 15 to 25 cm (6 to 10 in.). 

The solar radiation (sunlight energy) of the region is excellent for outdoor 

research and testing of solar energy conversion devices and systems. Sunshine is 

abundant throughout the year and remarkably consistent from month to month 

and season to season. 
NREL Environmental Report – 2001 Page 15 

Figure 2.1 – STM Site – Aerial view looking north, showing facilities and 

Conservation Easement lands. 

Figure 2.2 – STM Site – View looking northwest, showing Camp George West acreage 

acquired in 1999 and portions of the Pleasant View neighborhood. 
NREL Environmental Report – 2001 Page 16 

Figure 2.3 – STM Site – View looking east.

Figure 2.4 – STM Site – View looking southeast, showing portions of 

Pleasant View and Denver West Office Park. 
NREL Environmental Report – 2001 Page 17 

Figure 2.5 – NWTC – View looking northwest 

Figure 2.6 – NWTC – NW View with Turbine 
NREL Environmental Report – 2001 Page 18 

3. ENVIRONMENTAL PROGRAMS 

The objective of NREL’s environmental management program is responsible stewardship 

of the environment, both on its DOE-owned sites and leased properties. NREL strives to 

protect the natural environment by minimizing or eliminating any adverse environmental 

impacts resulting from NREL activities. The Laboratory’s environmental management 

program is integrated throughout all research and operations Centers and Offices. The 

program includes written environmental protection policy and program implementation 

documents. These are put into practice at all staff and management levels. 

NREL’s environmental management program includes components to address waste, air, 

water, natural resources, and land and soil issues, among others. Descriptions of the 

components of the environmental management program are provided in the following 

sections of this chapter. Sections are organized by resource. Each section is comprised 

of three areas of discussion: a summary of the environmental management of the 

resource, a discussion of any relevant permitting, and finally a summary of significant 

activities that have occurred throughout the year. 

A summary of the permits and notifications that have been issued by regulatory agencies 

for NREL activities is presented in Appendix B. These permits are discussed in the 

relevant sections below. 

3.1. Air Quality Protection 

3.1.1. Program Management 

Management in this area is consistent with the following NREL programs: 

Environmental Permitting and Notification (6-2.1), Air Quality Protection (6-

2.5), Ozone-Depleting Substances Management (6-2.6), and Particulate 

Emissions Control for Construction (6-2.14). 

Criteria, Hazardous, and Non-Criteria Pollutants 

The Clean Air Act and State of Colorado laws and regulations delineate several 

main categories for air pollutants: 

 Criteria air pollutants (e.g. carbon monoxide, nitrogen oxides, sulfur dioxide, 

particulate matter, ozone, and lead) 

 Hazardous air pollutants (e.g. includes organic compounds, metals, corrosives, 

asbestos, radionuclides, and pesticides) 

 Non-criteria pollutants (e.g. ammonia, hydrogen sulfide, pesticides, organic 

compounds, metallic compounds, corrosives, and ozone-depleting substances) 

 Ozone depleting substances (e.g. chlorofluorocarbons or “freons”) 

There are notification and permitting thresholds for criteria, hazardous, and noncriteria pollutants. Potential sources of these pollutants at NREL include boilers, 

emergency generators, experimental laboratory hoods, pilot scale research 

projects, and small pieces of equipment with gasoline or diesel engines. NREL 

maintains air emission inventories to track potential air emissions and identify 
NREL Environmental Report – 2001 Page 19 

whether notification and permitting could be required for a particular facility or 

activity. Fugitive particulate emissions from construction activities occurring on 

NREL’s sites are also a potential source. 

Ozone Depleting Substances 

Facilities that service refrigeration equipment containing ozone-depleting 

substances (ODSs) are required to file an annual notification with the Colorado 

Department of Public Health and Environment (CDPHE). This equipment 

servicing must be conducted by EPA-certified technicians, and NREL has 

certified technicians on staff that perform this type of service. 

Another requirement of the State of Colorado’s ODS program is that all 

refrigeration equipment larger than 100 hp that uses ODSs be registered with 

CDPHE. NREL has two chillers at its Solar Energy Research Facility (SERF) 

that are registered with CDPHE. 

Street Sanding 

CDPHE regulations require federal, state, and local government facilities to track 

wintertime street sanding, and to make efforts to minimize sand use. NREL 

complies with this requirement and files an annual sanding report with CDPHE. 

During the period of December 2000 to April 2001 NREL used 30 tons of sand 

during 11 sanding episodes. During the period of November 2001 to March 

2002, NREL used 17 tons of sand during 9 sanding episodes. NREL maintains 4 

lane-miles of roads. 

Vehicles 

NREL leases 48 vehicles from the General Services Administration. These 

vehicles are used for a variety of transportation and special purpose activities, 

such as equipment moving and servicing, grounds maintenance, and travel 

between the NREL sites. Thirty-four of the vehicles are classified as NonSpecial Purpose and are used as personal transportation only. Twenty three of 

these Non-Special Purpose vehicles are alternate-fuel vehicles, utilizing ethanol, 

diesel, or compressed natural gas (CNG). It is NREL policy to replace standard 

vehicles with alternative fuel vehicles whenever possible. The remainder of the 

vehicles are classified as special purpose and include vehicles such as delivery 

trucks, dump trucks, and pickup trucks. Two of the special-purpose vehicles are 

electric and the remainder of the vehicles are not available with alternative fuel 

options. 

3.1.2. Permitting 

Most potential sources of air emissions from NREL laboratory and facility 

operations in 2001 were small scale and did not require permitting. Permitting 

thresholds are generally 50, 500, 1000, or 2000 pounds, depending on the 

pollutant. Projected emissions for these sources were either below thresholds for 

air permitting or the state reviewed the operation and determined emissions to be 

negligible in terms of impacts to the environment. 
NREL Environmental Report – 2001 Page 20 

Two Air Pollutant Emissions Notices (APEN) and permit applications were filed 

with CDPHE in 2000 for the renewal of site wide permits covering particulate 

emissions from construction areas. One permit covers the STM site, and the 

other is in effect for the NWTC. These permits were received in March 2000. 

3.1.3. 2001 Activities 

No APENS were filed in 2001. 

Final permitting approval was obtained in April 2002 for the proposed scale-up 

of the experimental pilot scale Thermochemical Process Development Unit 

(TCPDU), located at the Field Test Laboratory Building (the APEN was filed in 

1999). 

3.2. Drinking Water 

3.2.1. Program Management 

Management in this area is consistent with the following NREL Programs: 

Drinking Water (6-2.3) and Environmental Permitting and Notification (6-2.1). 

Drinking water is provided to NREL’s STM and DWOP sites by a public water 

supply, Consolidated Mutual Water Company. Water to the JSF is also provided 

by a public water supply. NREL supplies drinking water to its NWTC by 

trucking in water from the Boulder public water supply through a subcontracted 

water hauler. NREL stores the water on site in an underground 15,000 gallon 

storage tank and an above ground 2000 gallon tank. The 15,000 gallon tank is 

filled by the water hauler, and water is pumped on demand to the 2000 gallon 

tank, where it is distributed to the Industrial User Facility (IUF) and Building 

251. 

Disinfection boosting is performed at the NWTC using a chlorine disinfection 

system, which was installed in June of 2000. An ultraviolet lamp system 

previously used for disinfection boosting was removed in November 2000. 

Testing for bacteria, lead, and copper is performed at the NWTC according to the 

requirements of CDPHE. In 2000, NREL filed an application requesting reduced 

monitoring for lead and copper, because historical monitoring results have 

consistently been below action thresholds established by the State. NREL 

subsequently received notice of qualification from the State for reduced 

monitoring. Current state requirements for NREL’s site are as follows: 

 Bacteria – monthly 

 Lead and copper – triennially 

 Chlorine residual – monthly, or more frequently as needed 

All samples are taken from one of the taps connected to the system. Bacteria 

were present in one sample collected in the IUF in October 2001 for total 
NREL Environmental Report – 2001 Page 21 

coliform. Following the receipt of these results, a total of five follow-up total 

coliform samples were taken from the IUF, Building 251 and the Pump House in 

October 2001. Total coliform was absent in all of the five follow-up samples 

collected. Follow-up sampling was repeated again in November 2001, and total 

coliform was absent from all five samples collected at that time. 

Although lead and copper monitoring was not required in 2001, as a best 

management practice, samples were collected from Building 251 and the IUF in 

September 2001 for both metals. Results were well below the action levels. 

According to NREL’s triennial schedule, monitoring for lead and copper will be 

conducted again during the summer of 2002. 

Chlorine residual monitoring of the NWTC drinking water system began with 

the installation of the chlorine disinfection system in 2000. Monitoring is 

performed to ensure the chlorine residual levels are detectable, with a target 

concentration of at least 0.2 mg/L of chlorine present to provide sufficient 

disinfection at the taps for both Building 251 and the IUF. The state requires that 

chlorine residual monitoring occur when collecting bacterial samples (monthly). 

NREL monitors chlorine residual levels in the system on a weekly basis and also 

measures chlorine levels of drinking water that is delivered to the NWTC. 

Monitoring results have shown the concentration of residual chlorine to be 

detectable since the chlorine disinfection system became operational. 

Although potable water delivered to the NWTC is from the Boulder supply that 

has already been treated and filtered, drinking water at the NWTC is filtered on 

site using a 1 micron filter. This would filter out any microorganisms (e.g. 

cryptosporidium or giardia) that are resistant to disinfection. The filters used by 

NREL are third-party tested to confirm that they actually filter particles as small 

as 1 micron in size. 

If any treatment is performed on supplied drinking water, state regulation 

requires that a State-licensed operator supervise the treatment. NREL hires a 

subcontracted operator with a Class A license to supervise the disinfection and 

filtration operations and to perform the necessary sampling. 

3.2.2. Permitting 

NREL has a Public Water Supply Identification Number (PWSID) issued by 

CDPHE for the drinking water it provides at the NWTC. This identification 

number does not require periodic renewal, but periodic testing and record 

keeping is required in connection with the PWSID. No identification is needed 

for NREL’s STM, DWOP, or JSF sites, as water is piped from another PWSID, 

Consolidated Mutual Water Company, and NREL does not alter or treat the 

water in any way. 
NREL Environmental Report – 2001 Page 22 

3.2.3. 2001 Activities 

An Operator in Responsible Charge report was filed with the State in 2001, as 

required. This report identifies NREL’s licensed operator. It will be kept current 

in the event NREL’s operator changes. 

In November of 2001 drinking water monitoring was performed in the FTLB, on 

the STM site, in response to building occupant concerns regarding the poor taste 

of the water. This monitoring involved collection of samples from multiple 

water outlets for turbidity, residual chlorine, total organic carbon, total coliform, 

nitrite, nitrate, sulfate, and 6 metals including chromium, copper, iron, nickel, 

lead and zinc. The monitoring results did not point to a source of the poor water 

taste, but revealed elevated levels of lead and turbidity at one of the drinking 

fountains. Extensive follow-up drinking water monitoring was performed for 

lead throughout the FTLB, which revealed that lead contamination was isolated 

to a few water outlets within the building. In those locations, the lead sources 

appeared to be within the outlets or the lateral piping leading to the outlets. 

Filters that remove lead were placed on the outlets that are used for drinking 

water and tested positive for lead. The remaining outlets testing positive for lead 

have restricted access and are not intended for drinking water purposes (i.e. 

custodial sinks); they were posted with signs prohibiting their use for drinking 

water purposes. Additional follow-up monitoring will be performed in late 2002 

when the lead filters are due for replacement. 

3.3. Ground Water Protection 

3.3.1. Program Management 

Management in this area is consistent with NREL’s Groundwater Protection 

Program (6-2.4). 

Because of the sensitive nature of the ground water resource, NREL is careful to 

evaluate all outdoor projects to attempt to eliminate their potential to impact 

ground water quality. If there are any materials used that could pose a potential 

ground water risk, the Laboratory typically insists that safeguards to protect 

ground water be established, such as secondary containment for equipment that 

could have the potential to leak oil, double wall tanks with leak detection for 

diesel fuel storage for NREL facilities’ emergency generators, and bermed areas 

to contain experimental materials. 

Ground water characterization was begun on the STM site in 1990 with the 

installation of a monitoring well network. Eight wells were installed at the base 

of the mesa slope. Four wells were installed upgradient of NREL development 

in order to provide an indicator that contaminants were not being transported 

onto the NREL site, and four wells were placed in a generally downgradient 

direction to verify that NREL activities had not adversely affected ground water 

quality. Quarterly sampling was performed for five calendar quarters, followed 

by annual sampling for three years. There was no evidence of contamination 
NREL Environmental Report – 2001 Page 23 

found. In addition, routine follow-up sampling was done in 1997. Three of the 

initial eight wells were closed (according to state requirements) due to 

construction activities in 1993, and a fourth was found to be inaccessible during 

the 1997 sampling, presumably also due to construction activity in the area. 

Therefore follow-up samples were only collected from four of the original 

monitoring wells: three upgradient wells and one downgradient of NREL 

development. No evidence of contamination was found in the 1997 sampling. 

NREL has not conducted groundwater monitoring at its leased DWOP site, as 

there have been no activities that pose an unusual risk to groundwater quality. If 

NREL had reason to suspect a groundwater quality problem, the issue would be 

addressed with Denver West Management. DWOP management contracted with 

an engineering firm to conduct a cursory groundwater monitoring study in 1988 

adjacent to the NREL-leased buildings. Two monitoring wells were drilled. 

There were no detections of significant levels of contaminants. 

The NWTC currently has no open or active groundwater wells. There was a 

water supply well that provided water to Building 251 when the site was 

operated by DOE's Rocky Flats Office. In 1993, NREL collected one round of 

water samples from this well and the associated water distribution and treatment 

system for the purpose of determining the most feasible alternative for water 

supply to the site. Based on the sampling results, it was determined that the 

maintenance and repairs required to make the existing well and treatment system 

effective were extensive, and there was an indication of the potential for trace 

organic compounds in the water. Therefore, when DOE's Golden Field Office 

assumed landlord responsibility for the site in 1993, the connection between the 

building and the well was severed. The water supply well was plugged and 

abandoned in accordance with state regulations by an NREL subcontractor in 

1996. Potable water is currently transported to the site, as described in Section 

3.2. NREL has not done any other groundwater sampling at the site. 

Groundwater sampling will be conducted if future activities pose a risk to the 

groundwater quality.

There has been no ground water study performed by NREL at the JSF, as NREL 

has not conducted any activities at the site that pose an unusual risk to ground 

water. All activities at the site are conducted inside the facility with the 

exception of routine deliveries and pick-up of inventory stored in the warehouse. 

There is currently no ongoing routine ground water monitoring program on any 

NREL site, because, with one exception, there have been no activities identified 

that currently or historically posed a significant risk to ground water. The one 

occurrence that had the potential to impact ground water was a diesel leak to the 

environment in June 1998 from a failed check valve on the PDU emergency 

generator above ground storage tank at the Alternative Fuels User Facility. The 

majority of contaminated soil was excavated and removed from the site for 

disposal at a permitted landfill. Three ground water monitoring wells were 

installed at the site in September 1998, one upgradient, and two downgradient. 

No hydrocarbon contamination was detected in the ground water during the 
NREL Environmental Report – 2001 Page 24 

initial sampling of the three wells, nor during follow-up sampling conducted in 

March and September 1999, and March 2000. Based on the results of these 

follow-up samples no further samples will be collected. 

3.3.2. Permitting 

All ground water monitoring wells installed by NREL at the STM site have been 

permitted with the Colorado Department of Natural Resources. Abandonment 

paperwork has also been filed with the State of Colorado for the three wells that 

were plugged in 1993. 

3.3.3. 2001 Activities 

Plans are being developed to close the three monitoring wells installed in 

September 1998. 

3.4. Wastewater Discharge 

3.4.1. Program Management 

Management in this area is consistent with NREL’s Waste Management and 

Minimization Program (6-2.8). 

The majority of wastewater from NREL’s STM and DWOP facilities flows into 

the Pleasant View Water and Sanitation District’s system and ultimately to 

Metro Wastewater Reclamation District’s (Metro) treatment plant. There is a 

small septic system consisting of a tank and absorption field, on the mesa top 

serving the Solar Radiation Research Laboratory (SRRL), because there is no 

sewer line to the mesa top. Wastewater from the JSF flows into the City of 

Arvada’s collection system where it is also routed to Metro’s treatment plant. 

The NWTC is not connected to a sewer system, but has two septic systems that 

include tanks and absorption fields for the treatment of wastewater. 

It is NREL policy that hazardous chemicals are not to be discharged to the sewer 

system, and NREL staff are trained in this policy. In addition, NREL sites have 

design criteria for waste drains in lab areas to minimize the possibility of a 

hazardous material discharge. These criteria include measures such as secondary 

containment for any chemicals used near sinks in laboratory exhaust hoods, no 

floor drains in laboratory areas unless a specific need can be shown, and caps for 

any floor drains that are installed in lab areas. New research and operations 

activities as well as ongoing activities that undergo significant modifications are 

reviewed for their potential effect on wastewater character through NREL’s risk 

assessment process. 

Quarterly wastewater monitoring at the DWOP leased facilities and at the STM 

site was initiated in mid-1992 and continued throughout 1994 to demonstrate that 

NREL facilities' wastewater effluent met local publicly owned treatment works, 

state, and EPA standards. Both 24-hour composite and grab samples were 
NREL Environmental Report – 2001 Page 25 

collected and demonstrated that discharges from Building 16 in the DWOP and 

the FTLB met all applicable regulatory standards. 

Manual grab sampling was also performed at the Building 15 photography 

laboratory wastewater sump with the same frequency as the other sampling 

during 1992 and 1993. The sump was decommissioned in 1994, and direct 

sampling of photo lab wastewater streams was conducted throughout 1994 to 

verify that standards were met. 

3.4.2. Permitting 

No permitting for the majority of NREL’s wastewater discharges is required. 

NREL has no direct wastewater discharges to the environment at the DWOP or 

JSF, so no National Permit Discharge Elimination System (NPDES) permitting 

is necessary. The only discharges at the STM and NWTC sites are through three 

individual sewage disposal systems, two at the NWTC and one at the STM site. 

The remainder of NREL facility wastewater is discharged to Metro through the 

sanitary sewer system. NREL facilities are currently classified as non-industrial 

water users at these sites because they discharge less than 97,633 L (25,000 gal) 

per day from each connection to the sewer system, and their effluent does not 

contain any toxic pollutants. As non-industrial users, NREL sites do not need a 

permit from Metro for sewer discharge, and monitoring for pollutants in 

wastewater is not required. 

NREL maintains septic permits from Jefferson County (an authority delegated 

to the counties under a State of Colorado program) for the NWTC septic systems 

as well as for the SRRL facility on the STM site mesa top. 

3.4.3. 2001 Activities 

In maintaining a septic permit for the SRRL, in February 2001 the Jefferson 

County Department of Health and Environment requested information regarding 

the volume of water discharged to the septic/leach system at the SRRL. NREL 

submitted a written report to the County, which detailed the total monthly water 

usage and estimated the daily water usage at the SRRL. The system was 

determined to be in compliance with its permitted capacity. The County 

requested that NREL continue to monitor the water usage at the SRRL until June 

2002 to verify the water usage stays within the limits of the septic system permit. 

3.5. Surface Water Protection (Storm Water) 

3.5.1. Program Management 

Management in this area is consistent with the following NREL Programs: 

Storm Water Pollution Prevention for Construction Activities at the STM, and 

Storm Water Pollution Prevention for Construction Activities at the NWTC (6-

2.15 and 6-2.16, respectively) 

Formatted: Bullets and Numbering
NREL Environmental Report – 2001 Page 26 

Limited storm water monitoring was conducted at the STM site during the 

summers of 1992 and 1993 to characterize surface water quality at NREL's 

existing level of activity at that time, and to confirm that NREL's activities were 

not adversely impacting storm water quality on the STM site. Sampling 

indicated that NREL's activities are not resulting in contamination of storm water 

runoff. 

No storm water monitoring has been conducted at NREL’s other sites. In 1998, 

surface water samples were taken in two drainages at the NWTC in connection 

with NREL’s weed control efforts. No traces of the herbicide applied to weedinfested areas were detected in the water samples. 

Outdoor research projects are reviewed during the planning stages, through 

NREL’s risk assessment program, for potential impacts to surface water. 

Measures to prevent such impacts are incorporated, as appropriate, into the 

design for each project. Such control measures could include secondary 

containment and bermed areas where chemicals will be used, or installation of a 

cover or roof to protect chemical use and storage areas from precipitation and 

adverse weather conditions. 

Storm Water Pollution Prevention Plans (SPPP) have been written for 

construction activities on both the STM and NWTC (6-2.15 and 6-2.16, 

respectively). Erosion and sediment controls are implemented according to the 

plans, and periodic site inspections are conducted to verify that the controls are 

functioning properly and to identify any repairs to the erosion and sediment 

controls that are needed. Written reports are issued for each inspection, with 

corrective actions assigned to responsible staff when necessary. The SPPPs also 

provide for prompt revegetation of disturbed areas. Provisions of the SPPPs are 

implemented through coordination with NREL’s construction subcontractors. 

3.5.2. Permitting 

NPDES permitting for storm water discharges on federal facilities in Colorado is 

under the jurisdiction of the Environmental Protection Agency (EPA). NREL is 

currently covered under EPA’s general permit for storm water discharge 

associated with construction activities on the STM and NWTC sites. Both 

Midwest Research Institute, as operator, and DOE, as site owner, have been 

issued permits. EPA has issued separate permit numbers for each owner and 

operator at each site for a total of four permit numbers. No permits are required 

for NREL’s routine operations. 

3.5.3. 2001 Activities 

In 2001 there were a few research-related and paving construction projects for 

which erosion and sediment control programs were developed. These were 

minor in terms of the extent of soil disturbance. There were no major 

construction projects in 2001. 
NREL Environmental Report – 2001 Page 27 

3.6. Waste Management

3.6.1. Program Management 

Management in this area is consistent with the following NREL Programs: 

Waste Management and Minimization (6-2.8), and Environmental Permitting 

and Notification (6-2.1). 

Hazardous wastes are handled and disposed according to the Resource 

Conservation and Recovery Act (RCRA). NREL facilities' waste profile consists 

of a broad range of hazardous laboratory chemicals in small quantities. 

Chemicals in solid or liquid form are collected in each laboratory or at each 

experimental site. These wastes are periodically collected from the laboratories 

and prepared by the NREL ES&H Office for off-site disposal. 

It is NREL's policy to have the majority of its RCRA-regulated wastes 

incinerated, rather than landfilled, in order to more completely destroy the 

hazardous constituents and minimize any potential for future public exposure. 

This treatment and disposal is conducted at an EPA-permitted treatment, storage, 

and disposal facility. In addition, NREL facilities have adopted a conservative 

waste disposal policy in which materials that are not regulated by RCRA, yet 

pose a potential hazard, are collected and disposed of as non-hazardous material 

at a RCRA-permitted disposal facility. 

NREL facilities also generate a very small amount of low level radioactive 

waste. The average amount of radioactive waste generated is typically less than 

1 cubic meter (about 10 to 20 kg) per year, including packing material. This 

waste normally consists of personal protective equipment such as gloves and 

water-based liquids. Radioactive waste is shipped off-site for disposal on an asneeded basis. 

As a facility that focuses on renewable technologies, NREL is committed to 

responsible environmental stewardship. A significant part of this effort is 

pollution prevention. NREL's Waste Management and Minimization Program 

outlines pollution prevention principles that are consistent with the EPA's 

hierarchy of preventing or reducing pollution at the source; recycling or reusing 

waste materials that cannot be prevented; and environmentally safe treatment and 

disposal of waste that cannot be prevented, recycled, or reused. 

The current pollution prevention program includes training on waste handling, 

waste minimization, and methods to eliminate releases to air, soil, or wastewater. 

In addition, the Environment, Safety and Health Office (ES&H) integrates 

pollution prevention awareness into NREL activities in a number of ways. The 

proposed use of chemicals in projects are evaluated prior to use during project 

planning reviews, Safe Operating Procedure reviews, and Readiness 

Verifications conducted according to NREL’s Hazard Identification and Control 

Program (ESH 6-6.2). During these reviews, NREL staff evaluate opportunities 
NREL Environmental Report – 2001 Page 28 

for chemical substitution as well as methods of reducing the volume of chemicals 

used and waste streams generated. 

The use of bankcards for chemical purchases has been another means of reducing 

the volume of chemicals purchased, stored and disposed at NREL. Under the 

chemical bankcard purchasing system, a small group of chemical users are given 

privileges to order chemicals directly from the vendor using their bankcards. 

Because bankcard purchasing expedites chemical purchases over conventional 

purchasing processes at NREL, users order only the chemicals they foresee 

they’ll need in the immediate future, knowing that they can quickly obtain more 

if needed. The ES&H Office reviews all purchases made using the chemical 

bankcards. 

Recycling and reuse activities are important components of NREL’s pollution 

prevention program. NREL currently has a volunteer Recycling Committee that 

has greatly contributed to expanding NREL’s recycling efforts. Items currently 

recycled or reused at NREL include the following: 

 fluorescent bulbs 

 waste oil containing no hazardous contaminants 

 batteries 

 styrofoam peanuts and other packing materials 

 freon from refrigerator units 

 cleaning solvents 

 scrap metal 

 wooden pallets 

 laser printer cartridges 

 aluminum and tin cans 

 glass 

 plastics (1 & 2 only) 

 newspaper 

 white and mixed paper 

 corrugated cardboard 

 boxboard 

 books and magazines 

 transparencies, and 

 tyvek envelopes 

Several central recycling locations are available for most recycling needs 

throughout NREL facilities. NREL also offers a chemical redistribution program 

where chemicals in original containers are made available to staff at NREL and 

other DOE facilities to be reissued for research activities at no cost. The process 

for redistributing chemicals to new users has been improved by the 

implementation of the chemical management system (CMS). 
NREL Environmental Report – 2001 Page 29 

When possible, NREL purchases products with recovered content. In 2001, 

some of the products purchased containing recovered content included carpeting, 

uncoated-printing paper, toner cartridges, file folders and notepads. 

3.6.2. Permitting 

NREL has four separate sites that have the potential to produce limited quantities 

of hazardous materials. Each of the four sites has a Resource Conservation and 

Recovery Act (RCRA) waste generator identification number issued by the State 

of Colorado. The South Table Mountain and Denver West Office Park locations 

are classified as "small quantity generators," generating less than 1000 kg of 

waste per month. The other two sites, the Joyce Street Facility and the National 

Wind Technology Center, are classified as "conditionally exempt small quantity 

generators," generating less than 100 kg of waste per month. 

3.6.3. 2001 Activities 

In 2001 NREL generated 27,780 pounds (12,627 kg) of hazardous waste, and 

4830 pounds (2,195 kg) of non-RCRA regulated waste. The total volume of 

hazardous waste included 2,585 pounds (1,175 kg) of batteries. The total 

amount of fluorescent bulbs shipped for recycling was 600 pounds (273 kg). 

These quantities are approximations only. The materials are normally not 

weighed when picked up by disposal or recycling vendors. Typically, a vendor 

will provide its good faith estimate of quantity based on practical experience. 

A small quantity of low level radioactive waste was shipped for off-site disposal 

in 2001, which included 482.32 MBq (0.013 mCi) of carbon-14, 0.092537 MBq 

(2.5 x 10-6 mCi) of tritium, and 4.144 MBq (0.0001 mCi) of uranium-239. Most 

of the radioactive waste shipped for disposal in 2001 resulted from the RAMP 

Industries, Inc. site abandonment and EPA emergency response, and details of 

this are included in Section 3.14.1. Information regarding the types and 

quantities of radioactive materials used at NREL facilities is detailed in Section 

3.14. 

In 2001, NREL participated in the DOE Exchange program by sharing the list of 

chemicals available for redistribution with other DOE facilities. This effort may 

contribute to waste reduction within the DOE organization. 

3.7. Storage Tanks (Underground and Above Ground) 

3.7.1. Program Management 

Management in this area is consistent with the following NREL programs: 

Aboveground Storage Tank Management (6-2.7) and Spill Prevention Control 

and Countermeasures (6-2.10) 
NREL Environmental Report – 2001 Page 30 

NREL facilities no longer have any underground storage tanks. Instead, NREL 

facilities store diesel for emergency generator and research use in aboveground 

storage tanks. The NREL tank inventory is presented in Appendix A.

NREL's tank management program focuses on proper tank design, operation, and 

inspection to protect against spills and leaks. The program is designed to meet 

regulatory requirements, and it is more stringent than the regulations require in 

many areas. 

Several important safeguards have been incorporated into NREL’s tank 

management program to prevent any accidental releases of diesel fuel from the 

storage tanks. These safeguards include both mechanical safeguards, such as 

double wall tanks with sensors that result in an alarm if the inner tank wall is 

leaking, overfill prevention, and spill protection; and procedural safeguards such 

as written operating procedures and tank filling procedures. All tanks larger than 

110 gallons are visually inspected at least once per month. 

Due to the quantity of diesel fuel stored on the STM site, a Spill Prevention 

Control and Countermeasures Plan is required to be in place. This Plan describes 

the site topography and neighboring areas, and outlines the steps necessary to 

mitigate any spills or leaks of diesel fuel. To date, NREL has not had any offsite 

impacts related to tank activities. 

3.7.2. Permitting 

Tanks larger than 660 gallons are required to be registered with the State of 

Colorado, with the registration renewed annually. Currently, only two tanks 

meet the registration threshold, the SERF emergency generator diesel storage 

tank and the Process Demonstration Unit (PDU) ethanol storage tank at the 

Alternative Fuels User Facility (AFUF), both located on the STM site. In 1999 

the State inspected each of NREL's registered tanks, and found no deficiencies in 

the management or operation of the tanks. 

3.7.3. 2001 Activities 

In April 2001, an operational surveillance of NREL’s Spill Prevention Control 

and Countermeasures (SPCC) Program was conducted by the DOE Golden Field 

Office in cooperation with NREL. The surveillance effort included review of 

applicable State and federal regulations, and a review of NREL’s SPCC Plan for 

the STM. The surveillance team also performed a site visit at several storage 

fuel tanks located at the STM and interviewed NREL personnel responsible for 

regulated facilities or materials. 

The surveillance team concluded that NREL’s SPCC Plan for the STM was 

clearly documented and met or exceeded the requirements of the applicable State 

and federal regulations. NREL ES&H staff members were found to provide 

excellent program management and oversight as well as support for the 

implementation process. Facility and maintenance personnel were well informed 

regarding the requirements of the program and closely follow SPCC Plan 
NREL Environmental Report – 2001 Page 31 

guidelines. Employees were knowledgeable regarding emergency response 

procedures. Observations noted in the surveillance report involved updating the 

emergency contact lists, adding location of manholes to the site map, and 

providing copies of the plan in facilities located near storage tanks. Since fuel 

tank management activities at the NWTC are not currently addressed in a sitespecific SPCC plan, a review is needed to determine if a SPCC plan is required 

at that site. 

There were no spills or leaks from NREL tanks during 2001. No state inspection 

was performed in 2001. The 2002 inspection will be discussed in the 2002 

annual report.

3.8. Hazardous Materials Management 

3.8.1. Program Management 

Management in this area is consistent with the following NREL programs: 

Chemical Safety Program (6-4.6), and Asbestos Management Program (6-4.18) 

No hazardous waste sites have been identified on any of the Laboratory sites. 

Therefore, many sections of the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) do not apply to NREL facilities. 

However, NREL sites are subject to the emergency reporting sections of 

CERCLA that require the reporting of any releases of reportable quantities (RQ) 

of chemicals. During 2001, the Laboratory had no releases to the environment of 

chemicals reportable under this section. 

NREL facilities are also subject to the emergency reporting requirements in Title 

III of the Superfund Amendments and Reauthorization Act (SARA), also known 

as the Emergency Planning and Community Right-To-Know Act (EPCRA). 

These regulations require a facility to notify the State Emergency Response 

Commission that it is subject to emergency planning and notification 

requirements if any chemicals in the facility's inventory are stored in quantities 

greater than prescribed threshold planning quantities (TPQs). NREL facilities 

first became subject to planning and notification requirements in 1988. 

There are also reporting requirements in the event of a release of an RQ of any 

hazardous substance listed by EPCRA. In 2001, NREL facilities had no release 

exceeding the RQ of any reportable material under EPCRA. 

NREL provides Material Safety Data Sheets (MSDSs) for chemicals that are 

stored on-site in quantities greater than TPQs, and provides inventory reporting 

for these same chemicals in the form of Tier I or Tier II reports to emergency 

planning and response groups. While NREL facilities currently have no 

chemicals on-site that exceed TPQs, the Laboratory has submitted MSDSs and 

Tier II reports in the past when required. 
NREL Environmental Report – 2001 Page 32 

NREL provides emergency response and reporting information to the Jefferson 

County Emergency Planning Committee (EPC), the State Emergency Response 

Commission, and West Metro Fire Protection District when requested. The 

Jefferson County EPC uses Uniform Fire Code hazard categories and threshold 

reporting quantities rather than those specified in SARA Title III, resulting in a 

larger number of individual hazard categories and lower reporting thresholds. 

NREL has an active involvement in the emergency planning concepts of SARA 

Title III, in that the Laboratory currently has an acting member on the Jefferson 

County EPC, and has been so represented since the EPC’s inception. 

SARA Section 313 requires that a toxic chemical release inventory report (Form 

R) be filed with EPA for any chemical that is manufactured, processed, or 

otherwise used in quantities exceeding TPQs. Although NREL is not a 

manufacturing facility and does not fall within any of the Standard Industrial 

Classification (SIC) codes for which Section 313 reporting is required, Executive 

Order 12856 requires all federal facilities to file a report, if applicable, regardless 

of SIC code. As a research and development Laboratory, NREL does not 

manufacture or process any materials, and during 2001, the Laboratory did not 

use any materials on the Section 313 list in quantities exceeding the 4536-kg 

(10,000-lb) threshold planning quantity. 

A Laboratory-wide chemical management system (CMS) was implemented at 

NREL in 1999. It serves as a centralized chemical inventory as well as a tool for 

managing and reporting on chemicals used at the Laboratory. Using an 

electronic barcoding system, the CMS tracks chemicals from the point of receipt 

through disposal. Key functions of the system include: 

 Providing current inventories by room, building, and/or site 

 Improving research efficiency and minimizing hazardous waste 

generation by allowing staff to determine if needed chemicals are 

already available on site prior to making chemical purchases 

 Providing quick access to chemical inventories and hazard information 

during emergency responses 

 Facilitating accurate and efficient reporting to external agencies (e.g. 

fire districts, EPC, EPA, DOE) 

 

To populate the CMS database, a physical inventory of each lab and work area in 

which chemicals are used or stored was conducted between June 1999 and the 

first quarter of 2000. 

In 2000, technical data and reporting information was entered into the system for 

many of the chemicals in the CMS database. 

NREL has not identified any areas within its facilities that contain residual 

contamination requiring special decommissioning. Asbestos surveys have been 

conducted in a number of NREL facilities: Joyce Street Facility; Building 251 at 

the NWTC; Building 16, and at the STM Site the AFUF (only older areas of the 

building), FTLB and SRRL. No asbestos was found at the Joyce Street Facility 
NREL Environmental Report – 2001 Page 33 

and the AFUF. The other facilities have limited amounts of asbestos-containing 

material in areas such as floor tile, lab countertops, caulking and sealants, and 

roofing material. Asbestos-containing materials are left undisturbed whenever 

possible. If renovation is planned that will disturb asbestos-containing material, 

then certified asbestos removal contractors are used and strict asbestos removal 

procedures are followed. An Asbestos Management Program is in effect for all 

NREL facilities. 

3.8.2. Permitting 

In 2001 NREL received Hazardous Material Permits from West Metro Fire 

Protection District. The permits are required by the Uniform Fire Code and the 

West Metro Fire Protection District and were issued by building. NREL 

obtained permits for a total of 7 buildings where hazardous materials are stored 

and/or used. Prior to issuing the permits, a representative from West Metro Fire 

Protection District conducted a walk-through inspection of the entire South Table 

Mountain Site and DWOP in May of 2001. There were no recommendations 

resulting from this inspection. 

3.8.3 2001 Activities 

The CMS was used to provide hazardous materials aggregate summary 

information to West Metro Fire Protection District when applying for Hazardous 

Materials Permits in 2001. The CMS was also used to post individual laboratory 

chemical inventories on the ES&H website, which were updated monthly. In 

2001, the search capabilities of the ES&H website were expanded to allow users 

to search for individual chemicals. 

A complete reinventory was conducted between August and October of 2001. 

The reinventory process involved verifying the inventory accuracy, as well as 

updating the hazard classification records. The results of the reinventory 

indicated that the NREL staff is in fact using the CMS as designed to track 

chemicals in their work areas. 

3.9. Vegetation Management 

3.9.1 Program Management 

Management in this area is consistent with NREL’s Weed Management 

Programs for the STM and NWTC (6-2.12 and 6-2.13, respectively). 

NREL’s basic philosophy regarding vegetation is to preserve and protect the 

ecosystems on the site in their natural state as much as possible. There is some 

landscaping using non-native drought-tolerant species adjacent to some of the 

buildings, and even a few areas at the STM site of sodded bluegrass. However 

the native vegetation and natural character of the landscape is maintained over 

the majority of the site. Revegetation of areas to be left in their natural state 

following disturbance from construction or other outdoor activities is conducted 
NREL Environmental Report – 2001 Page 34 

using a native seed mix of grasses and forbs. This mix is comprised 

predominantly of natives that were originally present on the site before 

disturbance. The use of native species is strongly encouraged at both the STM 

and NWTC sites whenever feasible. 

A vegetation survey of the STM site was conducted in support of the 1993 site 

wide Environmental Assessment, and a site reconnaissance was performed by 

Dames & Moore biologists in November 1997 (U.S. DOE, 1998, page 3-1). 

In 1999, a verification survey of STM site vegetation was performed on the 

Conservation easement property to identify any changes to habitat character or 

species types that may have occurred since the 1993 and 1997 surveys. An effort 

was made to determine whether any sensitive species or habitats that could 

potentially support such species were present on the site. No sensitive species or 

potential habitats were identified on the STM site. 

A vegetation survey of the STM was conducted between June 2001 and May 

2002. Details of the survey results are included in Section 3.9.3. 

A three-season vegetation survey of the NWTC site was performed between 

August 1999 and August 2000. The survey defined five general habitats on the 

NWTC site, comprising nine plant communities and 271 vascular plant species 

(Plantae Consulting Services, 2000). No rare or imperiled plant species were 

found on the site. However, the survey identified a small area of xeric tallgrass 

prairie (defined as mesic mixed grassland in this study) located in the southwest 

corner of the NWTC. This natural community is listed as rare and imperiled by 

the Colorado Natural Heritage Program. This listing implies no legal designation 

or regulatory enforcement. It is made primarily for management purposes. This 

area of the NWTC is not impacted by research or construction activities on the 

site. 

The survey identified eleven noxious weed species on the NWTC site. Five of 

these are recognized as belonging to the top ten prioritized weed species in 

Colorado. Based on the survey, recommendations were made to continue using a 

comprehensive weed management program, based on integrated pest 

management (IPM) philosophy. 

The survey showed the native seed mix used for revegetation at the NWTC to be 

very successful in many areas of the site. NREL is continuing the use of this 

seed mix for revegetation at the NWTC. 

Weed control efforts have been ongoing since 1997 at the NWTC and 1998 at 

the STM site. NREL uses an IPM approach that incorporates various types of 

weed control methods. Some of these include mechanical practices (e.g. 

mowing), cultural (reclamation of disturbed areas), prevention (e.g. limiting or 

eliminating driving of vehicles off established roadways), and herbicide 

treatment. The effectiveness of control methods is periodically assessed. The 

use of multiple strategies for control has been successful in significantly 
NREL Environmental Report – 2001 Page 35 

reducing populations of diffuse knapweed and Canada thistle on the sites. The 

key aspect of the weed control program is to maintain flexibility to respond to 

the changes in weed populations from year to year. 

In 1998, aerial herbicide application of Tordon 22K was conducted using 

helicopter application over about 200 acres of the NWTC to target diffuse 

knapweed. It has been very effective in controlling the weed, and healthy stands 

of native grasses have proliferated with the decrease in weed competition. Also 

at the NWTC in 1998, sensitive areas adjacent to drainage areas and trees were 

treated using ground application with the herbicide, Transline, to control diffuse 

knapweed, and small areas of Canada thistle were treated with Telar. Limited 

herbicide application occurred in 2000 and 2001, which included spot spraying 

using tractor and backpack applicators to target remaining pockets of diffuse 

knapweed and Canada thistle. More regarding 2001 herbicide application are 

provided in Section 3.9.3. 

Weed infestations at the STM site are much less severe than at the NWTC. 

Limited ground application of herbicides has been conducted at the STM from 

1999-2001, applying Transline and Tordon to diffuse knapweed and Telar to 

Canada thistle infested areas. 

3.9.2 Permitting 

There is no permitting applicable to vegetation management, although there is a 

State weed law that requires property owners to control certain species of 

invasive weeds (e.g. diffuse knapweed). For application of certain types of 

herbicides designated as “restricted use” by EPA, a certified applicator must be 

used. Herbicide applications at NREL are always performed by a certified 

applicator. The exceptions are herbicides used for control of undesirable 

vegetation along walkways, roadways, and adjacent to facilities. These are 

typically Round-Up and Weed-B-Gon and are applied by NREL Site Operations 

staff pursuant to an NREL Safe Operating Procedure (SOP). 

3.9.3 2001 Activities 

While NREL applies a variety of IPM practices, limited ground applications of 

herbicides occurred at the NWTC and STM in 2001. At the NWTC, spot 

spraying using tractor and backpack applicators was performed to target 

remaining pockets of diffuse knapweed and Canada thistle. Tordon and 

Transline were used to target diffuse knapweed. Tordon was applied in dry 

upland areas, while Transline was used near drainage areas. Tordon was also 

applied to small patches of leafy spurge. Telar was used to target Canada thistle. 

Escort was used in limited applications for common teasel, hoary cress, and 

sulfur cinquefoil. At the STM, Transline was applied to diffuse knapweed near 

drainage areas and near neighbor’s fence lines, while Tordon was used for 

diffuse knapweed in dry upland areas. Telar was applied to Canada thistle at the 

STM. 
NREL Environmental Report – 2001 Page 36 

A vegetation survey of the STM was conducted between June 2001 and May 

2002. Five general habitats were described on the STM site, comprising seven 

plant communities (Plantae Consulting Services, 2002). No rare or imperiled 

plant species were found in suitable habitat on the site. An area of mixed 

foothills shrublands was identified along the top of the mesa within the 

conservation easement area. While that natural community is listed as rare and 

imperiled by the Colorado Natural Heritage program, the listing implies no legal 

designation or regulatory enforcement. The listing is made primarily for 

management planning purposes. This area of the STM is minimally impacted by 

existing research facilities or other disturbances. 

Eleven noxious weed species were located on the STM site. Four of these 

belong to Colorado’s top ten prioritized-for-control weed species. These four 

include Canada thistle, diffuse knapweed, field bindweed, and musk thistle. 

3.10. Endangered Species/Species of Concern 

3.10.1. Program Management 

The Endangered Species Act provides for the designation and protection of 

wildlife, fish, and plant species that are in danger of extinction and preserves the 

ecosystems on which these species depend. A wildlife survey was completed on 

the STM site in 1987 (The FORUM Associates, Inc., 1987a), at which time no 

threatened or endangered species or candidate wildlife species for endangered 

designation were found. A vegetation survey of the STM site was completed in 

1999 for the National Renewable Energy Laboratory (NREL) Site Conservation 

Easement Baseline Inventory (U.S. DOE 1999). No threatened, endangered, or 

candidate plant species were identified in the survey. The most recent vegetation 

survey was completed between June 2001 and May 2002. Details of the survey 

are presented in Section 3.9.3. The survey found no rare/or imperiled plant 

species in suitable habitat on the site. 

Additional surveys of wildlife on the Conservation easement property were 

conducted in 1999, also for the Baseline Inventory. The U.S. Fish and Wildlife 

Service lists five threatened and endangered animal species that may potentially 

occur in the property area, including American peregrine falcon, bald eagle, 

Eskimo curlew, Mexican spotted owl, and Preble's meadow jumping mouse. The 

Colorado Natural Heritage Program database lists three animal species of interest 

that may potentially occur in the property area, including common shiner, arogos 

skipper, and ottoe skipper. No suitable habitat is present for any of these species 

on the Conservation easement property. 

No threatened, endangered, or candidate species of either plants or animals have 

been identified to date on the NWTC site. A vegetation survey conducted 

between August 1999 and August 2000 identified a small area of xeric tallgrass 

(defined in the survey as mesic mixed grassland) prairie located in the southwest 

corner of the NWTC site. This natural community is listed as rare and imperiled 

by the Colorado Natural Heritage Program. This listing implies no legal 
NREL Environmental Report – 2001 Page 37 

designation, but is made primarily for management planning purposes. This area 

is not impacted by current research and construction activities. 

Field research into avian use of the NWTC was conducted during 1994 and 1995 

in an effort to identify potential impacts on birds from wind-turbine research. 

While several species of raptors, including red-tailed hawks, kestrels, and a 

great-horned owl were noted on the site, they were primarily transient in nature. 

The NWTC appears to be used primarily for loafing and hunting, although one 

pair of kestrels nested in an old concrete pole during the spring. Birds of prey of 

concern, such as eagles, generally fly in excess of 152 m (500 ft) over the site. 

No significant impacts to the birds from NREL activities were found. 

The most recent research conducted for avian and bat use of the NWTC was 

conducted between May 2001 and July 2002. Details of the preliminary study 

results are included in Section 3.10.3. Final study results will be included in the 

2002 report. 

3.10.2 Permitting 

NREL has no permitting requirements for this area of environmental 

management. 

3.10.3 2001 Activities 

A year-long monitoring project for birds and bats was initiated on the NWTC in 

early 2001. Starting on May 30, 2001, standardized plot surveys were conducted 

to survey songbirds and raptors on the NWTC and adjacent, undeveloped areas. 

As of July 31, 2001, 15 species of songbird were recorded on the NWTC. The 

five most common species were vesper sparrow, western meadowlark, European 

starling, black-billed magpie, and cliff swallow (Armstrong et al., 2001). Several 

species of raptors were also observed on the NWTC; the most abundant species 

were American Kestrels and Red-tailed Hawks. 

Starting on May 29, 2001, NREL began conducting systematic searches of 

turbines and meteorological towers on the NWTC to document avian mortality. 

The study was completed in July 2002. As of November 15, 2001, three avian 

fatalities had been found, including a yellow-rumped warbler found under a guy 

wire supporting a meteorological tower, and American kestrel under a small 

turbine, and a black-billed magpie under a turbine with a lattice base (Armstrong 

et al., 2001). 

As part of the bird and bat survey at the NWTC, data collection to determine bat 

species composition and use of the area began in June 2001. Initial trapping 

surveys with mistnets have documented the presence of fringed myotis and big 

brown bats near the site. In August and September 2001, bat species were 

documented on the NWTC itself using bat detectors. The species identified 

included hoary bat, silver-haired bat, Mexican freetailed bat, long-legged myotis, 

small-footed myotis, and little brown myotis. Several bats have been observed 
NREL Environmental Report – 2001 Page 38 

on and near the NWTC foraging at heights similar to those occupied by turbine 

blades (Piaggo, 2001). Searches for bat carcasses near turbines have been 

conducted since late May 2001. No bat mortalities have been found at the site. 

A vegetation survey of the STM was completed between June 2001 and May 

2002. Details of the survey are presented in Section 3.9.3. The survey found no 

rare/or imperiled plant species in suitable habitat on the site (Plantae Consulting 

Services, 2002). An area of mixed foothills shrublands was identified along the 

top of the mesa within the conservation easement area. While that natural 

community is listed as rare and imperiled by the Colorado Natural Heritage 

program, the listing implies no legal designation or regulatory enforcement. The 

listing is made primarily for management planning purposes. This area of the 

STM is minimally impacted by existing research facilities or other disturbances. 

3.11. Wetlands/Floodplains 

Limited wetland areas totaling less than 0.2 ha (0.50 ac) occur on the STM site in 

the drainage bottom located north of the Visitor’s Center. These are narrow, 

linear wetlands supporting spikerush, baltic rush, sedges, bluegrass, hemlock, 

and field mint. These wetlands will be protected from adverse impacts as site 

development continues. 

Wetland areas at the NWTC are extremely limited in extent as well. These areas, 

along the site’s eastern boundary, total less than 0.4 ha (1 ac). 

According to maps generated by the Jefferson County Department of Highways 

and Transportation as part of its urban drainage studies, NREL's STM site does 

not contain any floodplains, and no floodplains have been identified at the 

NWTC. As a best-management practice, however, all construction activities that 

may cross a drainage channel are designed to meet the 100-year flood control 

standards (designed to withstand the equivalent of a 100-year flood). 

3.12. Cultural Resources 

Two formal surveys of historic and cultural resources have been performed on 

the STM site. These surveys were completed in 1980 and 1987. As a result of 

these surveys, three historical sites were recognized as significant cultural 

resources that should be preserved. These sites include an open-air 

amphitheater, a stone bridge spanning a natural drainage channel adjacent to the 

amphitheater, and a stone and concrete ammunition bunker below the 

amphitheater site. The three structures were constructed during the Works 

Progress Administration (WPA) era in the 1930s. Through NREL's efforts, these 

sites have been added to the National Register of Historic Places (National 

Register), with the amphitheater and stone footbridge listed together as a single 

site. NREL also participated in an interagency survey of South Table Mountain 

and Camp George West to identify historic structures and sites eligible for 

nomination to the National Register. 
NREL Environmental Report – 2001 Page 39 

An archaeological survey of the NWTC site was conducted in support of the 

1996 Environmental Assessment to supplement previous surveys so there were 

no gaps in cultural surveys on the site. No significant historical or 

archaeological resources were identified. However, the wooded ridge area on the 

west portion of the site was identified as a location with potential for cultural 

resources, so further testing or observation during excavation would be done 

should there be any future need for work in the utility corridor in the vicinity of 

the ridge. 

3.13. National Environmental Policy Act (NEPA) 

3.13.1. Program Management 

Management in this area is consistent with NREL’s NEPA Implementation 

Program (6-2.2). 

As a federal agency, DOE is obligated to comply with NEPA by evaluating the 

potential for environmental impacts prior to conducting its activities. 

Regulations for compliance with the Act are issued by the Council of 

Environmental Quality (CEQ). DOE has also issued implementing regulations at 

10 CFR that complement the CEQ requirements. DOE has written a site wide 

Environmental Assessment (EA) for its activity at the STM Site and DWOP, and 

separate EAs for the NWTC and JSF activities. 

NREL has established procedures, with the approval of the DOE GO, to assist 

DOE in meeting their NEPA obligation. Proposed activities that will be 

conducted off of NREL’s four sites are evaluated for their potential 

environmental effects using the appropriate level of NEPA review, in 

conjunction with GO. 

The NREL NEPA Handbook has been prepared to provide NREL project 

managers and procurement specialists with guidance on implementing the NEPA 

procedures. 

3.13.2. Permitting 

NREL has no permitting requirements under NEPA. 

3.13.3. 2001 Activities 

During 2001, activity continued on developing EAs for 3 potential sites for 

small-scale geothermal power plant construction. In 2001 site visits were made 

for a second time at all three sites including Empire, Nevada, Animas, New 

Mexico, and Newcastle, Utah. An EA was begun in 2000 for a geothermal site in 

Empire, Nevada and continued in 2001. The EA for the Newcastle, Utah site 

was initiated in 2001, then put on hold in early 2002. The EA will not be 

completed, as the project will not proceed to the construction phase. The EA for 
NREL Environmental Report – 2001 Page 40 

the Animas, New Mexico site was also initiated in 2001 and a FONSI was signed 

for the site in 2002. 

Project information for several geothermal direct use projects was reviewed in 

2001. The EA process was initiated in 2002 for one of these projects, which is 

located in Canby, California. 

In 2001 a subcontractor was hired and began writing the new Site wide EA for 

the NWTC, and the EA was completed in May 2002. 

Internal scoping began in 2001 for the new Site wide EA for the STM. In 2002 

the contractor was hired and began writing the EA. The EA for the STM is 

scheduled to be completed in late 2002. 

In addition to the EA activity, numerous NEPA reviews of both onsite and offsite 

activities occurred through completion of NREL Environmental Checklists. As 

outlined in NREL’s NEPA implementation procedures, these reviews were 

coordinated with NREL project managers, subcontracting staff, the NREL NEPA 

Coordinator, and the DOE Golden Field Office NEPA Compliance Officer. 

NEPA requirements were also coordinated with future program planning through 

interaction between NREL’s NEPA Coordinator and NREL’s Technology 

Program and Project Managers. 

3.14. Radiological Program 

3.14.1Program Management 

Management in this area is consistent with the following NREL programs: Air 

Quality Protection (6-2.5), and Radiological Control (6-4.5). 

All radioactive material at NREL facilities are handled according to NREL’s 

Radiological Control Program. Elements of the program include a radiological 

control organization, a radiation safety policy and control manual, safe operating 

procedures, safe work permits, radiological control areas and postings, 

monitoring, training, and purchasing controls for radioactive materials. 

There are no nuclear operations at NREL sites. The majority of radiation sources 

are used/stored in facilities located on the STM site. These include three x-ray 

diffraction machines at the SERF and two sealed source level gauges at the 

AFUF used on pilot scale processes to measure the level of material inside 

process tanks. In addition, two laboratories at the Field Test Laboratory Building 

(FTLB), on the STM site, occasionally use small quantities of radioisotopes for 

biological or chemical labeling, and in 2001 one laboratory in the SERF used a 

small quantity of depleted uranium to perform temperature dependant 

conductivity and photoconductivity measurements. 

The three X-ray diffraction machines are registered with the State of Colorado 

and are inspected every two years by a state-licensed surveyor. The surveyor 
NREL Environmental Report – 2001 Page 41 

inspects and certifies the X-ray machines and audits NREL's program for 

radiation safety in connection with operating the machines. An inspection of one 

of the X-ray diffraction machines was performed in February 2001, and the other 

two machines were re-inspected in November 2001. Re-certification will occur 

in two years. 

 

Personal monitoring by way of thermoluminescence dosimeters (TLDs) is 

performed on NREL personnel who are working with x-ray machines or in labs 

where P-32 radioisotopes are handled or stored. C-14, S-35, and H-3 cannot be 

detected using the TLDs. Each worker wears a TLD that is sent to a laboratory 

for analysis at least once every quarter. In 2001 there were TLD monitoring 

results for 21 people. All of the exposure results were at background levels, with 

the exception of the result for one worker. This researcher used P-32 in 

accordance with Radiation Safe Operating Procedure #663, and during the first 

quarter in 2001 his ring badge received a dose result of 0.63 rem, which was 

about 1 % of the annual extremity (e.g. hand) limit of 50 rem. Although this 

exposure was above background, it was well below the allowable annual limit. 

The work practices of this researcher were reviewed by NREL’s Radiation 

Safety Officer, and it was determined that no unusual handling activities 

occurred that would have contributed to this low exposure. Workers 

periodically have low exposures while working with P-32 given it is a highenergy beta emitter. Exposures during the remainder of the year for this activity 

were at background levels. 

Monitoring of equipment and facilities for removable contamination is 

performed in the laboratories where radioisotopes are used. Wipe tests are 

performed on any laboratory surfaces that could have become contaminated by 

the radioisotope work at least monthly and more frequently if needed. These 

wipes are analyzed using a scintillation counter. 

U.S. Department of Energy (DOE) Order 5400.5, “Radiation Protection of the 

Public and the Environment,” established radiation emission limits for DOE 

facilities. Such emissions are also regulated by Section 112 of the Clean Air Act 

as implemented by 40 CFR 61, Subpart H, established by the U.S. 

Environmental Protection Agency (EPA). According to 40 CFR 61, Subpart H, 

all DOE facilities, including NREL, must annually demonstrate compliance with 

the radionuclide emission limit to the ambient air not exceeding an amount that 

would result in any member of the public receiving an effective dose of 10 

mrem/yr or greater. No radioactive air-emission monitoring is conducted at 

NREL because of the extremely low usage of radioactive material. Therefore, 

NREL demonstrates compliance with the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) in 40 CFR 61, Subpart H, by utilizing the 

EPA’s COMPLY computer model to determine the effective dose equivalent to 

the public. 

During 2001, the total quantity of radioisotopes used was 2.016 mCi used in one 

laboratory at NREL’s FTLB and one laboratory at the SERF. Any emissions 

generated by this work were emitted by a laboratory hood exhaust. In addition, 
NREL Environmental Report – 2001 Page 42 

much of NREL’s radioisotope inventory (including waste quantities) is in 

containers on which the manufacturer’s original seal was broken. In 2001 the 

potential dose to the public was calculated as though the contents of all unsealed 

containers was exhausted to the atmosphere, including the amount actually used 

in 2001. P-32 and S-35 waste that is stored in the Waste Handling Facility and 

has decayed past ten half-lives was not included in this calculation. 

The distance from the source in the FTLB to the nearest potential receptor is 119 

m (fence line of nearest resident). For the SERF, the distance from source to the 

nearest potential receptor is 256 meters. For the WHF, the distance from the 

source to the nearest potential receptor is 311 m. These distances are greater 

than in previous reports due to a land acquisition and resulting changes in site 

boundaries. 

According to the COMPLY computer model, the potential dose to the nearest 

member of the public is 0.2 mrem/yr, below the emission limit of 10 mrem/yr, 

and NREL is in compliance with the NESHAP for radionuclides. Because the 

dose is calculated rather than measured, it represents a potential or estimated 

rather than an actual dose. 

The resulting calculated off-site whole body doses are small, but are still likely 

overestimates of potential radionuclide doses. The COMPLY formula assumes 

that the entire quantity of the radionuclide in all open containers was released, 

and that the receptor raises and consumes all his/her own milk, meat, and 

vegetables at home. These assumptions are extremely conservative. 

All radioactive waste generated during NREL activities is classified as low level 

waste. Waste from the STM site is temporarily stored at the Waste Handling 

Facility (WHF) until disposal is arranged at an offsite facility permitted to accept 

low level radioactive waste. The total amount of low level radioactive waste 

shipped off-site for disposal in 2001 was as follows: 482.32 MBq (0.013 mCi) of 

C-14, 4.144 MBq (0.0001mCi) of U-239 and 0.092537 MBq (2.5 x 10 -6 mCi) of 

H-3. This waste included the disposal of approximately 300 pounds of 

radioactive waste resulting from the RAMP Industries, Inc. site abandonment 

and EPA emergency response. This waste, shipped to RAMP Industries, Inc. on 

June 24, 1993 and returned to NREL October 23, 1995, had been in storage at 

NREL’s WHF pending authorization for final disposal. During this storage 

period, NREL complied with the EPA’s requirements regarding the storage of 

RAMP-related waste, and provided an annual status report detailing this storage. 

On January 22, 2002, the EPA provided documentation to NREL stating we had 

properly complied with the terms of the storage and disposal agreement, and 

EPA considers the matter closed. 

3.14.2 Permitting 

NREL does not have a radioactive materials license from the State of Colorado, 

as the Laboratory is currently under DOE jurisdiction for radioactive materials 

handling. 
NREL Environmental Report – 2001 Page 43 

3.14.3 2001 Activities 

During 2001, the total quantity of radioisotopes used was 2.016 mCi, and 

included the use of C-14, P-32, H-3, and depleted U-238. NREL’s total 

inventory of radioactive isotopes (excluding waste) at year-end 2001 (inventory 

taken in January 2002) is as follows: 

Isotope Activity 

C-14 6.079 mCi (7.9 x 107

 Bq) 

S-35 0 

H-3 1.0 mCi (3.7 x 107

 Bq) 

P-32 0.36 mCi (1.3 x 107

 Bq) 

 

Total 7.439 mCi (1.29 x 108 Bq) 

In 2001 NREL performed a self-assessment of the Radiation Safety Program and 

the management of radioactive waste. This assessment was conducted by an 

independent health physicist. As a best management practice, the assessment 

criteria were based upon State of Colorado radiation safety standards, these 

standards being the most suitable for the risks present at NREL. Overall, the 

self-assessment findings indicated that NREL’s programs were performing well, 

and included only minor deficiencies. 

In 2001 there was no construction or modifications to the labs where 

radioisotopes are used. 

There were no unplanned releases of radioisotopes in 2001. 

4. GREENING OF THE GOVERNMENT THROUGH LEADERSHIP IN 

ENVIRONMENTAL MANAGEMENT 

In March 2000, Executive Order 13148, Greening the Government Through Leadership 

in Environmental Management was issued, requiring that all Federal agencies ensure that 

environmental accountability is integrated into day-to-day decision making and long-term 

planning processes. In February 2001, DOE issued a notice (DOE N 450.4) outlining 

requirements for DOE contractors under Executive Order 13148. NREL is complying 

with these requirements as detailed in this section. 

Environmental Management Systems: 

Under this executive order DOE facilities are required to implement an Environmental 

Management System (EMS) as part of a Integrated Safety Management (ISM) System. 

During the development and implementation of the NREL ISM system in 1998 through 

2000, the Lab took a number of actions to ensure the EMS was part of ISM. The 

Environmental Management Policy (6-2) and 16 supporting Lab-level programs that 

define the NREL EMS were carefully coordinated and linked with the ISM Policy (2-1), 

the ES&H Policy (6-1), the supporting ES&H Policies (6-3 through 6-6), and 
NREL Environmental Report – 2001 Page 44 

approximately 40 supporting Lab-level safety and health programs. The EMS is further 

integrated with ISM via task specific procedures that flow down from the policies and 

programs, such as Safe Operating Procedures (SOP). 

In 1999 NREL operations were assessed against the criteria defined in ISO 14001. 

Policies and programs were revised as necessary to incorporate the applicable ISO 

criteria for the hazards and operations present at NREL. 

With support from Midwest Research Institute a self-assessment of all environment, 

safety and health programs was conducted in 1998 and 1999 against a commercially 

available audit criteria, the Common Audit Process (CAPTM). Use of these audit criteria 

gave added confidence that environmental management programs were fully integrated 

with safety and health programs, and that the majority of ISO 14001 criteria for an EMS 

were met. Based on the self-assessment results, necessary changes were made to the 

policies and programs. 

Environmental Management System Auditing: 

NREL has EMS auditing processes in place for the set of policies, Lab-level programs, 

and task specific procedures. NREL reviews its ES&H policies as needed, but at least 

every 3 years, and makes revisions as necessary. In coordination with the Golden Field 

Office (GO) ES&H Surveillance Program, NREL has established an ES&H selfassessment program. A specific set of Lab-level programs are selected for assessment 

each year based on criteria established by the NREL/GO Operations Team, with the 

selected set including environmental programs that are part of the EMS. The EMS Lablevel programs evaluated in 2000 include the Aboveground Storage Tank Management 

Program (6-2.7) and the Storm Water Pollution Prevention Programs for the STM and 

NWTC (6-2.15 and 6-2.16, respectively). In 2001, the Spill Prevention Control and 

Countermeasures Program (6-2.10) was evaluated. Details of the surveillance and selfassessment of that program are presented in Section 3.7.3. In 2002 an assessment of 

NREL’s environmental management processes will be completed. Results of this 

assessment will be presented in the 2002 report. 

All SOPs are reviewed on an annual basis and are revised as necessary to help ensure the 

required controls are appropriate for the hazards present. Environmental hazards and 

controls are specifically called out in each SOP. 

EPCRA Compliance and Prevention of Toxic Releases: 

E.O. 13148 maintains requirements for SARA Title III, Emergency Reporting and 

Community Right-to-Know Act (EPCRA) compliance and Toxic Release Inventory 

reductions for government facilities. NREL maintains hazardous materials permits with 

and provides chemical inventory information to the authorities having jurisdiction (e.g. 

fire districts, haz mat teams) under EPCRA. 

In 2001, NREL facilities had no release exceeding the reportable quantity (RQ) of any 

reportable material under EPCRA. 

As a research and development laboratory, NREL does not manufacture or process any 

materials, and during 2001, the Laboratory did not use any materials on the SARA 
NREL Environmental Report – 2001 Page 45 

Section 313 list in quantities exceeding the 4526-kg (10,000 lb) threshold planning 

quantity. 

NREL’s compliance with EPCRA requirements is detailed in Section 3.8. 

NREL maintains an Emergency Management Policy (8-4) and supporting lab-level 

programs, including an Emergency Response Team Program (8-4.1), for credible on site 

emergencies. Hazardous material releases are specifically called out as a credible 

emergency, and response procedures are in place. These procedures are routinely 

practiced by internal response groups and with external emergency response agencies. 

Pollution Prevention Initiatives: 

As a facility that focuses on renewable technologies, NREL is committed to a pollution 

prevention program. NREL addresses pollution prevention through the Waste 

Management and Minimization Program (6-2.8), waste minimization criteria 

incorporated into all SOPs under the Hazard Identification and Control Program (6-6.2), 

and a recycling program managed by a volunteer committee that includes representative 

members from NREL’s Staff Council. Details of NREL’s pollution prevention program 

are outlined in Section 3.6. 

Wetlands Protection: 

Limited wetland areas totaling less than 0.2 ha (0.50 ac) occur on the STM site in the 

drainage bottom located north of the Visitor’s Center. These are narrow, linear wetlands 

supporting spikerush, baltic rush, sedges, bluegrass, hemlock, and field mint. These 

wetlands will be protected from adverse impacts as site development continues. 

Wetland areas at the NWTC are extremely limited in extent as well. These areas, along 

the site’s eastern boundary, total less than 0.4 ha (1 ac), and will also be protected from 

adverse impacts. 

Floodplains Management:

According to maps generated by the Jefferson County Department of Highways and 

Transportation as part of its urban drainage studies, NREL's STM site does not contain 

any floodplains, and to date, no floodplains have been identified at the NWTC. As a 

best-management practice, however, all construction activities that may cross a drainage 

channel are designed to meet the 100-year flood control standards (designed to withstand 

the equivalent of a 100-year flood). 

Actions undertaken by NREL at subcontractor facilities are assessed for potential impacts 

on floodplains at those sites through the use of an environmental checklist. 

Sustainability Practices: 

Sustainable landscaping is an integral part of the planning that occurs prior to 

construction and renovation, as well as day-to-day maintenance, of NREL facilities. 

NREL’s basis philosophy regarding vegetation is to preserve and protect the ecosystems 

on the site in their natural state as much as possible. For the most part, the native 

vegetation and natural character of the landscape is maintained at the STM and the 

NWTC. Revegetation of areas disturbed from construction or other outdoor activities is 
NREL Environmental Report – 2001 Page 46 

conducted using a native seed mix of grasses and forbs. The use of native species is 

strongly encouraged at both the STM and NWTC whenever feasible. Details of NREL’s 

vegetation management programs and activities are outlined in Section 3.9.1. 

NREL also focuses on sustainability by incorporating sustainability building features in 

the conceptual design phases of major facilities, implementing building efficiency 

improvements, encouraging public transportation by providing RTD Eco-Passes to 

employees, and subscribing to the Xcel Energy Green Power program. 

In FY 2001, NREL established the Sustainable NREL Initiative to pursue additional areas 

of sustainability improvement. As an outcome of that initiative, an NREL Sustainability 

Master Plan was approved in 2002 that details goals and implementation strategies to 

advance sustainability at NREL. More information about specific activities will be 

provided in the 2002 report. 

Class 1 Ozone-Depleting Substances (ODSs) Phase-Out 

NREL has controls for the use of ODSs in the Ozone-Depleting Substances Management 

Program (6-2.6). Section 3.1.1 details NREL’s servicing and registration of equipment 

containing ODSs. 

Halon-based fire suppression systems used at NREL were eliminated by 1999, with all 

supplies of Halon being transferred to other DOE facilities for “banking”. 

5. CONSERVATION EASEMENT LANDS 

During 1999, DOE placed 177 acres of the STM site in a Conservation Easement. The 

purpose of the Conservation Easement is to preserve the natural character of the property, 

including its visual, biological, and recreational resources, especially in relation to the 

changing land uses adjacent to the NREL site and within the region. 

The goals of the easement are to: 

 Retain, preserve and protect natural, scenic, ecological, and historical aspects of the 

conservation easement property; 

 Protect the ecosystem of the South Table Mountain area and the sustainable habitat 

for biodiverse vegetation, birds, and terrestrial animals; 

 Ensure the scenic and biological integration with adjoining open-space land; 

 Prevent further industrial, commercial, or residential development of the 

conservation easement property; and 

 Preserve the conservation easement property as natural open space. 

A baseline inventory of the property was prepared in June 1999 to document the current 

condition of the easement property and to assess the conservation value of the property 

(Department of Energy, Golden Field Office, 1999). The baseline inventory includes a 

description of the geographical setting and adjacent property owners, access and use of 

the property by the public, and a description of the existing environmental conditions of 

the property (geology, hydrology, vegetation, wildlife, cultural resources). There are also 

photos incorporated into the report that document the condition of the property. 
NREL Environmental Report – 2001 Page 47 

2001 Assessment of the Property:

During 2001 there was no NREL activity on the conservation easement property having 

the potential to degrade the environmental condition of the property. A site inspection 

was conducted by Jefferson County Open Space, NREL, and DOE during the summer of 

2002. No degraded conditions or other environmental issues were found. Photos taken 

in 2000 showing the representative areas of the easement lands are included in Section 2 

of this report. 

6. NON-ROUTINE ACTIVITIES/SPECIAL PROJECTS 

A complete re-inventory of the CMS was conducted between August and October of 

2001. The re-inventory process involved verifying the inventory accuracy, as well as 

updating the hazard classification records. The results of the re-inventory indicated that 

the NREL staff is in fact using the CMS as designed to track chemicals in their work 

areas. 

 

7. ENVIRONMENTAL OCCURRENCES 

There was one environmental occurrence during 2001 at the STM site, and one at the 

NWTC. 

At the STM site, on July 10, 2001, a small amount of floor stripper was spilled on the 

floor of SERF Lab W214. The spill was contained to a small area within the lab, and was 

easily cleaned up by the ES&H Office staff without any releases to the floor drains or the 

environment. 

At the NWTC site, on September 18, 2001 a series of oil filled capacitors located in the 

Variable Frequency Drive overheated during operation of the dynamometer in the 

Dynamometer Test Facility (DTF). One capacitor leaked a small amount of oil inside the 

DTF, which was easily contained and effectively cleaned up. There was no 

environmental damage to the site and no reportable releases as a result of this incident. 

8. SUMMARY OF ONGOING ENVIRONMENTAL ACTIVITIES 

In 2002, a working group was convened to develop a master plan for future development 

of NREL’s STM and NWTC sites. The plan is being developed with a 25 year outlook. 

More information on the master site planning effort will be provided in the 2002 report. 

The 2002 Environmental Management System (EMS) Assessment evaluated NREL 

management processes with a focus on environmental components. It also evaluated the 

link between the EMS and NREL’s sustainability initiative. The assessment resulted in 

recommendations for improving the EMS as well as synergies between the EMS and 

sustainability program to improve their effectiveness. In the upcoming year, NREL will 

be working to implement these recommendations. 
NREL Environmental Report – 2001 Page 48 

9. REFERENCES 

Armstrong, D.,C. Bock, T. Piaggio, and E. Schmidt (2001). NWTC Site wide Bat and 

Avian Impact Study Plan: May 1, 2001-July 31, 2002. 

EG&G Rocky Flats, Inc., (1992). Rocky Flats Plant Site Environmental Report, January 

Through December 1992. Golden, Colorado. 

Handex of Colorado, Inc. (1997). Groundwater Monitoring Report, South Table 

Mountain Site. Golden, Colorado 

National Renewable Energy Laboratory, (Draft). ES&H Program Number 6-2.12, 

Weed Management Program, STM Site. Golden, Colorado. 

National Renewable Energy Laboratory, (1997). National Renewable Energy Laboratory 

Environmental Report for 1995 and 1996. Golden, Colorado. 

National Renewable Energy Laboratory, (1999a). National Renewable Energy 

Laboratory Five-Year Plan, 2000-2004. Golden, Colorado.

National Renewable Energy Laboratory, (1999b). NREL Policy Number 6-2, 

Environmental Management. Golden, Colorado. 

National Renewable Energy Laboratory, (1999c). NREL Policy Number 6-6, Risk 

Assessment. Golden, Colorado. 

Piaggio, T., Doctoral Candidate, Environmental, Population, and Organismic Biology, 

University of Colorado, Boulder, telephone, communication. July 18, 2001. 

Plantae Consulting Services, (2000). Vegetation Survey, NREL National Wind 

Technology Center. Boulder, Colorado. 

Plantae Consulting Services, (2002). Vegetation Survey, NREL South Table Mountain 

Site. Boulder, Colorado 

Rust Environment & Infrastructure, Inc., (1993). Water Quality Monitoring, National 

Wind Technology Center. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1994a). Final Report, Baseline Surface Water 

Monitoring Program: 1993. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1995a). Report, Wastewater Monitoring 

Program, Fourth Quarter, 1994 and Annual Report. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1995b). Final Report, Ground Water 

Monitoring, Third Quarter, 1994 and Fourth Annual Report, South Table Mountain Site. 

Englewood, Colorado. 
NREL Environmental Report – 2001 Page 49 

U.S. Department of Energy, Golden Field Office, (1999). National Renewable Energy 

Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 

U.S. Department of Energy, (1998). Environmental Assessment, Right-of-Way Easement 

For Public Service Company of Colorado at the South Table Mountain Site, Golden, 

Colorado. DOE/EA-1254. 

U.S. Department of Energy, (1993). Site wide Environmental Assessment for the 

National Renewable Energy Laboratory, Golden, Colorado. DOE/EA-0850. 

10. APPENDICES 

Appendix A – Above Ground Storage Tank Inventory 

Appendix B – Summary of NREL Environmental Permits, Registrations, Notifications 
NREL Environmental Report- 2001 Page 50

APPENDIX A - ABOVEGROUND STORAGE TANK INVENTORY 

Tank 

ID 

Size Contents Class Use Date On-Line Service 

Status 

Date Last 

Change in 

Status 

 No. 1 1010 gallons Diesel II FTLB Emergency Generator 

(UST) 

1983 Closed 

(6/96) 

6/96 

No. 2 800 gallons Diesel II SERF Emergency Generator 10/93 In-Service 

 Double-walled, interstitial monitor, no secondary containment 

No. 3 6000 gallons Ethanol, 50% IC PDU Ethanol Storage 12/95 In-Service 

 Single-walled, remote monitoring, 7500 gal concrete containment 

No. 4 564 gallons Diesel II PDU Emergency Generator 8/95 In- Service 6/15/98 OS 

9/11/98 IS 

 Double-walled, interstitial monitor, no secondary containment 

No. 5 560 gallons Diesel II FTLB Emergency Generator 6/96 In-Service 

 Double-walled, interstitial monitor, concrete secondary containment 

No. 6 400 gallons Diesel II IUF Emergency Generator 3/97 In-Service 

 Double-walled, no secondary containment 

No. 7 80 gallons Diesel II 251 Emergency Generator 1980 PC No. 8 500 gallons Diesel II NWTC Hybrid Power Test 

Bed (HBTB) Convault, popup interstitial monitor 

 6/97 In-Service 

 No. 9 500 gallons Diesel II Bldg 16 Emergency Generator 

Single-walled, no interstitial 

monitor, 537-gal secondary 

containment 

1990 In-Service 

No. 10 100 gallons Diesel II NWTC NPS Daytank 

Double-walled, no interstitial monitor 

6/96 In-Service 

No. 11 100 gallons Diesel II NWTC HPTB North Daytank 

(SIM#1) Single-walled, no interstitial monitor 

6/97 In-Service 
NREL Environmental Report – 2001 Page 51 

 Tank 

 ID

 Size Contents Class Use Date On-Line Service 

Status

Date Last 

Change in 

Status 

No. 12 100 gallons Diesel II NWTC HPTB South Daytank 

(SIM#2) Single-walled, no interstitial monitor 

6/97 In-Service 

 No. 13 50 gallons Diesel II SunWize (West of HPTB) 

Single-walled, 36-gal steel catch basin 

5/98 NC 

No. 14 200 gallons Diesel II 251 Stand-by Generator 

Double-walled, no interstitial monitor 

9/98 In-Service 

No. 15 100 gallons Diesel II AFUF Emergency Generator 

Double-walled, no interstitial monitor 

6/94 TC 10/2000 TC 

No. 16 50 gallons Diesel II Bergey Hybrid System 

(Site 1.8)  Double-walled, no interstitial monitor 

1/00 NC 

No. 17 173 gallons Diesel II NWTC Hybrid 80 (Sim #4) 

Double-walled, no interstitial monitor 

3/01 In-Service 

No. 18 336 gallons Diesel II NWTC Hybrid 125 (Sim #3) 

Double-walled, no interstitial monitor 

3/01 In-Service 

No. 19 500 gallons Propane - NWTC East Met Tower - NC No. 20 500 gallons Propane - NWTC West Met Tower - NC No. 21 500 gallons Propane - Capstone Micoturbine - NC 

Service Status  In-Service (IS)  Out-of-Service (OS)  Temporary Closure (TC)  Permanent Closure (PC)  Change-In-Service (CIS)  NC—not covered by this Program 
NREL Environmental Report – 2001 Page 52 

APPENDIX B – SUMMARY OF NREL ENVIRONMENTAL PERMITS, REGISTRATIONS, NOTIFICATIONS 

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or 

Reg. 

Holder 

Permit Type Permit Description Issuing 

Agency Name

Location Description 

Status/ Expiration 

Date 

Reporting Required 

Permits 

1 00JE0010L DOE AIR Air Emission Permit 

for Land Development (fugitive dust from construction activities)

Colorado Dept. of Public Health and Environment (CDPHE) 

NWTC site 1/31/05 (issued 3/1/00) N/A 

2 95JE497L DOE AIR Air Emission Permit 

for Land Development (fugitive dust from construction activities)

CDPHE STM site 1/31/05 (issued 3/1/00) N/A 

3 COR10A59F DOE STORM WATER Storm Water 

(sitewide) -- discharge associated with construction activities 

U.S. Environmental Protection Agency (EPA)

NWTC site 2/17/03 (permit issued 

by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

4 COR10A60F MRI STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities 

EPA NWTC site 2/17/03 (permit issued 

by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

5 COR10A57F DOE STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities 

EPA STM site 2/17/03 (permit issued 

by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

6 COR10A58F MRI STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities 

EPA STM site 2/17/03 (permit issued 

by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

7 37232 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-1) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

8 37229 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-2) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 
NREL Environmental Report – 2001 Page 53 

Tracking Number

Permit or Registration Number

Permit or Reg. Holder

Permit Type Permit Description Issuing 

Agency Name

Location Description

Status/ Expiration Date

Reporting Required

9 37228 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-3) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

10 37231 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-4) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

11 37230 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-5) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

None 

12 214960 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-11) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

13 214961 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-10) 

Colo. Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

14 214962 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-09) 

Colo Div. Of Water Resources 

STM construction complete, 

permit number active until well is closed 

none 

15 99JE0400 NREL/DOE Air TCPDU air emissions CDPHE STM initial approval issued 

7/20/2000 

None 

16 20020347 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Building 16 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

17 20020348 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

SERF 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

18 20020349 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Waste Handling Facility 

2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

19 20020350 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

FTLB 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually
NREL Environmental Report – 2001 Page 54 

Tracking Number

Permit or Registration Number

Permit or Reg. Holder

Permit Type Permit Description Issuing 

Agency Name

Location Description

Status/ Expiration Date

Reporting Required

20 20020351 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

AFUF 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

21 20020352 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Shipping & Receiving Facility 

2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

Notifications and Registrations 

22 PWSID Number 

230860 

DOE DRINKING 

WATER 

Non-community supply of hauled water from a surface water source 

CDPHE NWTC site N/A Periodic chlorine residual 

testing; monthly bacteriological testing; periodic lead and copper monitoring 

23 CO4890000017 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE DWOP update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

annual fee to Colorado Hazardous Waste Commission 

24 CO3890090076 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE STM update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

annual fee to Colorado Hazardous Waste Commission 

25 COD980805162 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE JSF update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

none 

26 COD983802448 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE NWTC update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

none 
NREL Environmental Report – 2001 Page 55 

Tracking Number

Permit or Registration Number

Permit or Reg. Holder

Permit Type Permit Description Issuing 

Agency Name

Location Description

Status/ Expiration Date

Reporting Required

27 00407-001 and 

00407-002 

DOE AIR: OZONE 

DEPLETING SUBSTANCES 

Registration of stationary appliances (2 SERF chillers) 

CDPHE SERF annual renewal due 

July 1 

none 

28 N/A DOE AIR: OZONE 

DEPLETING SUBSTANCES 

Facility Notification CDPHE STM, NWTC annual notification and 

fee 

29 2873-001 and 

2873-002 

DOE ABOVE 

GROUND STORAGE TANK 

Registration of aboveground storage tanks 

Colorado Dept. of Labor

STM--PDU Ethanol Storage Tank, SERF Emergency Generator Tank 

annual registration and fee, due April/May 

none 

30 93000378 DOE Historic 

Registration 

National Register of Historic Places 

National Park Service 

Colorado Amphitheater 

no expiration none 

31 93000379 DOE Historic 

Registration 

National Register of Historic Places 

National Park Service 

Ammunition Igloo 

no expiration none 

32 AFP-CO-00255 DOE Alcohol (not an 

environmental permit) 

Alcohol Producer's Permit 

Bureau of Alcohol, Tobacco, and Firearms 

AFUF (PDU) annual renewal due 

July 1 

annual report due Jan 30 

33 TF-CO-0331 DOE Alcohol (not an 

environmental permit) 

Industrial Alcohol User Permit 

Bureau of Alcohol, Tobacco, and Firearms 

NREL-wide annual renewal due 

July 1 

none 

34 N/A NREL Transportation Hazardous Material 

Transportation 

U.S. Department of Transportation

NREL-wide annual renewal and fee none